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Metra Chem is distinguishable from the instant case. The
computation of the income of a mortgage lending business
conducted in S corporation form, which must be reported on the
shareholders' individual returns without regard to whether it is
distributed to them, is a more complex undertaking than the
straightforward reporting of a cash dividend received by a C
corporation shareholder. The erroneous income figure for Windsor
($414,845) appeared only on a worksheet to the Schedule E
attached to petitioner's Form 1040. That figure required a
further offsetting adjustment before being reported on the face
of the Schedule E as $378,428. Thus, only a rather detailed
tracing through the Schedule E worksheet would have alerted
petitioner to the error at issue. Moreover, even assuming
petitioner had spotted the erroneous $414,845 income figure, that
number approximated the $412,000 distributed to him from Windsor
during 2001. Thus, petitioner may have surmised, as a layman
relying on accountants, that he was reporting as taxable income
from Windsor the amounts distributed to him. In sum, the
discrepancy here arose in the context of reporting a transaction
(an S corporation shareholder's recognition of passthrough income
from a mortgage lender) that was more complex, and less
transparent, than that at issue in Metra Chem.
To be sure, the $173,093 discrepancy here was large, but
smaller in relative terms than the errors made by the taxpayers'
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