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deliberate. As further evidence of his asserted good faith,
petitioner testified that he submitted an installment payment
request before an assessment was made on his account and that he
made four payments totaling $1,345.
Receipt of a Form 1099-MISC is not required to remind a
taxpayer of income that must be reported on his or her Federal
income tax return. Brunsman v. Commissioner, T.C. Memo. 2003-
291. The gross amount of the distribution, $16,263, represented
approximately 24 percent of petitioner’s total taxable income for
2003. Petitioner’s argument that he did not remember this
distribution at the time he filed his 2003 return because of the
extraordinary demands of his job as an attorney is without merit.
Finally, as respondent correctly argued at trial,
petitioner’s contention that his attempt to pay off the tax
through an installment agreement shows his good faith is
irrelevant under these facts and circumstances. What controls
here is petitioner’s good faith at the time the return was filed,
rather than the action he took after he received the notice of
deficiency. Sec. 6664(c)(1). Accordingly, we sustain
respondent’s determination with respect to the accuracy-related
penalty under section 6662(a).
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