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his tax treatment of his Johnston Island wages as nontaxable income.
In Hautzinger v. Commissioner, T.C. Memo. 2003-236, decided
by this Court on August 8, 2003, respondent did assert and we did
sustain imposition of an accuracy-related penalty, but, as
stated, such penalty related to the false reporting by the
taxpayer that his wages were earned in American Samoa rather than
in Johnston Island, where the wages in fact were earned.
Petitioner herein is not liable for the section 6662(a)
accuracy-related penalty with respect to his tax understatement
relating to his Johnston Island wages.
To reflect the foregoing,
Decision will be entered
for petitioner.
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