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place to stay. Petitioner also fell behind on paying bills and
student loans. Although petitioner eventually found a new job,
it paid close to minimum wage and provided no health benefits.
Petitioner sustained at least one injury from an accident while
he was uninsured, and he had to pay the related expenses out of
pocket.
The record is unclear as to whether petitioner received the
Form 1099-MISC, Miscellaneous Income, issued by Onyx.3 Given the
circumstances described herein, it seems unlikely that petitioner
would have appreciated the significance of the Form 1099-MISC
even if he did receive it, even though failure to receive a Form
1099-MISC does not necessarily constitute reasonable cause for
failure to report income. See Goode v. Commissioner, T.C. Memo.
2006-48.
We find that petitioner’s termination from employment, his
eviction resulting in temporary homelessness, his health issues,
and the technical nature of the law as to the exclusion of income
under section 104 are factors that weigh in his favor. Viewing
all the facts and circumstances, including the experience,
knowledge, and education of the taxpayer, we conclude that
petitioner has demonstrated reasonable cause for failing to
3 The parties stipulated that petitioner received the
settlement proceeds, and that Onyx issued a Form 1099-MISC, which
was submitted as an exhibit. The record does not state that
petitioner actually received the Form 1099-MISC.
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