- 14 - issue or give undue dignity to petitioner's argument by reiterating what has been set forth above. As we stated in Harris v. Commissioner, T.C. Memo. 1981-46, “To anyone * * * not incorrigibly addicted to the ‘free lunch’ philosophy of life, the entire scheme had to have been seen as a wholly transparent sham." Based upon the record in the instant case, we find that petitioner’s actions do not approach the actions that a reasonable and ordinarily prudent person would have taken under the circumstances. See Chamberlain v. Commissioner, supra at 733. Accordingly, petitioner is liable for the additions to taxdue to negligence under section 6653(a)(1) and (2) for the taxable years at issue. Respondent is sustained on this issue. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011