Tunji and Christina Mabinuori - Page 13

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          1099-MISC for the earnings during the training period.  Thus,               
          petitioners could have reasonably concluded the Form W-2 reported           
          the entire earnings from MetLife in 2002.  It is arguable that              
          petitioners should have noticed their gross income was                      
          understated by $6,005.  However, petitioners believed that a                
          significant portion of this amount was reimbursement for office             
          expenses and, therefore, excludable from gross income.  The facts           
          present a close question, but viewing the record as a whole, we             
          conclude that petitioners have demonstrated reasonable cause for            
          failing to report the self-employment income and that they acted            
          in good faith.  See sec. 6664(c).  Accordingly, they are not                
          liable for the accuracy-related penalty with respect to this                
          adjustment.                                                                 
























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