- 11 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008