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as belonging to Mr. Bell. If the copies of the Forms 1096 for
both 1999 and 2000 petitioners admitted into evidence were
authentic, it seems highly unlikely that the Social Security
Administration would mistakenly omit Mr. Bell’s information for
both years. Respondent questioned the authenticity of the copies
of Forms 1096 for 1999 and 2000 petitioners admitted into
evidence, and petitioners presented no proof the Forms 1096 were
actually filed for years 1999 and 2000. In light of petitioners’
dubious record keeping and lack of clear and credible testimony,
the Court agrees with respondent’s conclusion that the copies of
Forms 1096 for 1999 and 2000 were not authentic. Petitioners
presented no additional evidence, such as canceled checks,
establishing the payments to Mr. Bell during these 2 years.
Consequently, the Court sustains respondent on this issue.
Petitioners are not entitled to any deduction for wages for 1999
and 2000 in excess of the amounts conceded by respondent.
Respondent determined section 6662(a) penalties against
petitioners in the amounts of $2,751 for 1999 and $3,341 for
2000. Section 6662 provides for the imposition of a 20-percent
penalty for the portion of any underpayment to which the section
applies. Sec. 6662(a). Respondent determined that section
6662(b)(1) applied to petitioners because petitioners were
negligent or disregarded rules or regulations.
Negligence is defined as “any failure to make a reasonable
attempt to comply with the provisions of this title.” Disregard
includes “careless, reckless, or intentional disregard”. Sec.
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