-3-
an accuracy-related penalty under section 6662(a); and (3)
whether jurisdiction is available to consider petitioners’ claim
for suspension of interest under section 6404(g).
FINDINGS OF FACT
Some of the facts are stipulated and are found accordingly.
The stipulation of facts, the supplemental stipulation of facts,
and the attached exhibits are incorporated herein by this
reference. At the time of the filing of their petition,
petitioners resided in Washington, D.C.
Petitioner Jesse Goode was employed by the District of
Columbia (the District) for approximately 8 years when placed on
paid administrative leave on January 19, 2000. At that time, he
was serving as the general counsel to the District’s Department
of Human Services. (Petitioner Tawara Goode is a party to this
case solely because she filed a joint Federal income tax return
with petitioner Jesse Goode for the taxable year at issue, and
references herein to petitioner in the singular are to Jesse
Goode).
Precipitating the District’s adverse employment action
against petitioner was a series of news reports in the Washington
Post probing numerous, deplorable incidents of neglect and abuse
suffered by residents of the District’s housing facilities for
individuals with developmental disabilities, which was under the
aegis of the Department of Human Services. On January 17, 2001,
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