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to report the IRA distributions during 1999 as taxable income,
but they also failed to report any of the dividend income in the
amount of $6,093.21 earned by the IRA during 1999.
Petitioners assert that they are not liable for the
accuracy-related penalty under section 6662(a) for three reasons.
First, petitioners claim that, at the time they filed their 1999
return, they did not know whether the rollover in 1998 was valid
because “respondents [sic] never answered their several
assistance appeals” and petitioners had not received the Form
1099-R for 1999 from Norwest. Second, petitioners assert that
respondent has determined their liability for the accuracy-
related penalty “to hide their [sic] [respondent’s] negligence of
not responding to petitioners appeal for assistance with the ESOP
transaction". Third, petitioners assert that they “exercised
extreme duty of care towards to the ESOP transaction issue under
severe circumstances of being abroad and seriously ill”.
In summary, petitioners argue that, before they filed their
1999 return, they asked for advice from respondent concerning the
validity of the rollover in 1998, and, when they received no
response from their inquiries from respondent, they did the best
they could under the circumstances of being abroad and with Mr.
Kopty’s health issues. Petitioners appear to invoke the
reasonable cause exception under section 6664(c) which provides
that no penalty shall be imposed with respect to any portion of
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