Ronald C. McKee and Anita L. McKee - Page 4

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               For 2001, Autocar paid to Mr. McKee total wages in the                 
          amount of $21,666.2  For that year, Autocar issued to Mr. McKee             
          two Forms W-2, Wage and Tax Statement.3  On the first such Form             
          W-2 (first W-2), Autocar reported wages paid to Mr. McKee in the            
          amount of $7,891; on the second such Form W-2 (second W-2),                 
          Autocar reported wages paid to Mr. McKee in the amount of                   
          $13,775.  Mr. McKee received the first W-2; however, he did not             
          receive the second W-2.                                                     
               Petitioners timely filed a joint Federal income tax return             
          for 2001.  On their return, petitioners reported wages from                 
          Autocar in the amount of $7,891, as reflected on the first W-2,             
          and they attached to their return a copy of that W-2.                       
          Petitioners did not report, on their 2001 return, wages from                
          Autocar in the amount of $13,775, as reflected on the second W-2.           
               Petitioners did not compare the $7,891 of wages reported on            
          the first W-2 with the total “year-to-date” wages reported on the           
          final pay stub for 2001 from Autocar.  Indeed, petitioners did              
          not look at the first W-2; rather, they placed it in a tax folder           
          provided by petitioners’ income tax return preparer and then                
          forwarded that folder to the preparer.                                      




               2  All monetary amounts are rounded to the nearest dollar.             
               3  The record does not disclose why Autocar would have                 
          issued two Forms W-2 to Mr. McKee for the same taxable year.                





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