Lance Brown - Page 10

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          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 was            

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