George Georgiou and Judith Georgiou A.K.A. Judy Georgiou, et al. - Page 42

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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                                 

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