Tyrone Sharp and Alvera Sharp, a.k.a. Alvera Crockett - Page 13

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          proving that he or she did not act negligently or disregard rules           
          or regulations.  Rule 142(a); Welch v. Helvering, 290 U.S. 111,             
          115 (1933).                                                                 
               Respondent supports the imposition of the section 6662(a)              
          accuracy-related penalty entirely on petitioner’s failure to                
          include the Social Security disability benefits in his 1999                 
          income.                                                                     
               We are satisfied that petitioner made a good faith effort to           
          properly determine his 1999 Federal income tax liability, and his           
          failure to properly account for his Social Security disability              
          benefits results from an honest misunderstanding of fact or law             
          that is reasonable in light of the his experience, knowledge, and           
          education.  Accordingly, we hold that petitioner is not liable              
          for the section 6662(a) accuracy-related penalty for his 1999 tax           
          year.                                                                       
               Reviewed and adopted as the report of the Small Tax                    
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be                    
          entered under Rule 155.                                                     











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