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to substantiate that the advances to Georgiou were loans. The
Holding Agreement, Supply Agreement, promissory notes,
adjustments to books and records, and minutes were either created
or altered, and backdated, in an attempt to deceive the IRS
agent. (At the conclusion of trial, respondent moved to amend
the answer to allege fraud. The motion was denied as untimely.)
Georgiou testified that he did not read many of the
documents he signed in either his individual capacity or as
president of Kolonaki. Even if he did not read them, we
attribute knowledge of the documents to him. See Bollaci v.
Commissioner, T.C. Memo. 1991-108. The voluntary failure to read
a return and blind reliance on another for the accuracy of a
return are not sufficient bases to avoid liability for negligence
additions to tax. Id. See, e.g., Bagur v. Commissioner, 66 T.C.
817, 823-824 (1976), remanded on other grounds 603 F.2d 491 (5th
Cir. 1979); Bailey v. Commissioner, 21 T.C. 678 (1954).
Petitioners' assertion that they relied on their
professional advisers is unpersuasive and incredible.
Accordingly, we sustain respondent's determination that
petitioner Georgiou is liable for the section 6662(a) accuracy-
related penalties for 1989 and 1990 and that petitioner Kolonaki
is liable for the section 6662(a) accuracy-related penalty for
1990.
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