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received compensation from CEMAX for his services. See Brunsman
v. Commissioner, T.C. Memo. 2003-291.
Taxpayers have a duty to read a return and to make sure all
items are included. Magill v. Commissioner, 70 T.C. 465, 479-480
(1978) (citing Bailey v. Commissioner, 21 T.C. 678, 687 (1954)),
affd. 651 F.2d 1233 (6th Cir. 1981). At trial, Mr. Sullivan
agreed with this point. The omission of the CEMAX Form W-2
resulted in petitioners' failure to include almost one-third of
their income on their original return. Petitioners' failure to
carefully review their return was not reasonable. See Guenther
v. Commissioner, T.C. Memo. 1995-280. On the basis of the
record, the Court concludes that petitioners are liable for the
accuracy-related penalty under section 6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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