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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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