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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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