- 10 - and it remains relevant as further evidence to consider. See Wright v. Commissioner, 84 T.C. 636 (1985); Castillo v. Commissioner, 84 T.C. 405, 409-410 (1985); Curry v. Commissioner, T.C. Memo. 1991-102; Whyte v. Commissioner, T.C. Memo. 1986-486, affd. 852 F.2d 306 (7th Cir. 1988). Petitioner's claim that the underreporting of income was caused by his tax return preparers is not supported by the evidence. For both 1986 and 1987, petitioner disclosed inaccurate information to his tax return preparers, and petitioner is not allowed to now shift to his return preparers responsibility for his failure to accurately report his income. Alexander Shokai, Inc. v. Commissioner, 34 F.3d 1480, 1486 (9th Cir. 1994), affg. T.C. Memo. 1992-41; United States v. Claiborne, 765 F.2d 784, 798 (9th Cir. 1985). Petitioner argues that the revenue agent's initial proposal of the negligence addition to tax for 1986 indicates that the evidence does not support a finding of fraud. At that time, however, respondent’s agent was not aware that petitioner had failed to disclose various bank accounts and the correct amount of commissions and fees received in 1986 and 1987. Only after respondent’s revenue agent discovered the additional bank account and the additional unreported income did respondent’s revenue agent make the fraud referral. Petitioner argues that because his amended 1987 Federal income tax return reported income over and above income that wasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011