- 10 -
Finally, as respondent correctly points out, because neither Form
W-2 was marked as having been corrected, it was not reasonable
for petitioner and his accountant to believe, without questioning
petitioner’s employer, that only one of the Forms W-2 was
correct.
Although this close case might have been more equitably
resolved by the parties, this Court is constrained to apply the
full penalty or no penalty at all. Because petitioner has not
demonstrated reasonable cause and good faith for the
underpayment, the Court sustains respondent’s imposition of the
section 6662(a) penalty.
The Court has considered all of petitioner’s contentions,
arguments, requests, and statements. To the extent not discussed
herein, we conclude that they are meritless, moot, or irrelevant.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: November 10, 2007