C. Richard Roose, Jr. and Betty B. Roose - Page 13

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                    [Petitioners contend] that * * * [they], being                    
               unversed in matters of accounting, relied totally upon                 
               * * * [Reed] to insure the accuracy of * * * [their]                   
               records and prepare * * * [their] tax returns.  * * *                  
               [Petitioners] further contend that the resultant                       
               understatements are not such as would cause * * *                      
               [petitioners] to be aware that * * * [their] income was                
               underreported.  We cannot agree with either contention.                
                    At the outset we are not impressed with * * *                     
               [petitioners'] attempt to characterize * * *                           
               [themselves] as * * * unknowledgeable * * *                            
               [businesspeople].  * * * the record shows that * * *                   
               [the Rooses had their] fingers on the pulse of the                     
               financial affairs of * * * [Roose Drug Store].                         
                    * * * [Petitioners'] conduct was intimately                       
               entwined with the inaccurate recording of * * * [their]                
               business income.  * * *                                                
                    While a taxpayer's reliance upon his accountant to                
               prepare accurate returns may indicate an absence of                    
               fraudulent intent, John Marinzulich [v. Commissioner],                 
               31 T.C. 487, 490 (1958), this is true in the first                     
               instance only if the accountant has been supplied with                 
               all the information necessary to prepare the returns.                  
               Petitioner[s] [argue] in this regard that * * * [Reed]                 
               had total access to all of * * * [petitioners'] books                  
               and records, so that even though the * * * [Drug Topics                
               book] was inaccurate, a thorough professional job of                   
               accounting would have uncovered the inaccuracies.  Of                  
               course the thorough audit by respondent's agents did                   
               discover many omitted and erroneous entries.  However,                 
               we cannot conclude on the basis of the record before us                
               that * * * [Reed] was retained to check with * * *                     
               [petitioners'] customers in order to find out whether                  
               they made payments to * * * [petitioners] which were                   
               not recorded in the * * * [Drug Topics book] or to                     
               otherwise doublecheck the * * * [Drug Topics book]                     
               entries made by * * * [Mrs. Roose].  The evidence                      
               points to the contrary.  * * *  [Id. at 162-163; fn.                   
               ref. omitted.]                                                         
               Considering the entire record, we conclude that respondent             
          has proven by clear and convincing evidence that the entire                 
          amount of the underpayments of tax on petitioners' returns for              





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