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Accuracy-Related Penalty
Year Deficiency Under Sec. 6662(a)
1999 $16,935 $3,387.00
2001 17,586 3,517.20
The only issue remaining for decision is whether petitioners
are liable for 2001 for the accuracy-related penalty under
section 6662(a). We hold that they are.
FINDINGS OF FACT
All of the facts in this case, which the parties submitted
under Rule 122, have been stipulated by the parties and are so
found.
Petitioners resided in Hermiston, Oregon, at the time they
filed the petition in this case.
Starting around June 1998, L. Ben Smith (Mr. Smith) began
working for Raytheon Demilitarization Company (Raytheon) on
Johnston Island. Around April 1998, shortly before Mr. Smith’s
employment with Raytheon began, Mr. Smith attended an orientation
session presented by Raytheon (Raytheon’s orientation session).
During Raytheon’s orientation session, Raytheon orally informed
Mr. Smith that Johnston Island was not tax exempt and that he was
to be liable for tax on the compensation that he earned while
working on Johnston Island. Around June 1, 1998, after
Raytheon’s orientation session, Raytheon issued a so-called
1(...continued)
tice and Procedure.
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