- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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