Ronald C. McKee and Anita L. McKee - Page 3

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               For the taxable year 2001, respondent determined a                     
          deficiency in petitioners’ Federal income tax in the amount of              
          $5,574 and an accuracy-related penalty under section 6662(a) in             
          the amount of $860.                                                         
               Petitioners concede that they are liable for the deficiency            
          in income tax as determined by respondent.  Thus, the only issue            
          for decision by the Court is whether petitioners are liable for             
          the accuracy-related penalty on that deficiency.  We hold that              
          they are.                                                                   
          Background                                                                  
               This case was submitted fully stipulated under Rule 122.  We           
          incorporate by reference the parties’ stipulation of facts and              
          accompanying exhibits.                                                      
               Petitioners resided in Roseville, California, at the time              
          that their petition was filed with the Court.                               
          A.   Petitioner Ronald C. McKee’s Commission Income                         
               Petitioner Ronald C. McKee (Mr. McKee) worked as a car                 
          salesman for Autocar Inc. of Roseville (Autocar), California,               
          from 1998 through May 2001.  Mr. McKee was paid on a commission             
          basis for his services as an employee of Autocar.                           
               From January through May 2001, Mr. McKee received a paycheck           
          from Autocar every 2 weeks, along with a pay stub showing his               
          wages for the 2-week period and his “year-to-date” wages.                   







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