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Commissioner, 380 F.2d 499, 506 (5th Cir. 1967); Neely v.
Commissioner, 85 T.C. 934, 947 (1985)). Petitioner is an
experienced businessman and insurance agent. There is evidence
in the record that petitioner through GAPS created and maintained
a fairly complex record-keeping system to document and administer
the employee benefit programs of his business clients. However,
when it came to his own affairs and those of his wholly owned
corporations, petitioner did not institute and implement similar
procedures for creating and maintaining documentation.
Petitioner never produced any loan source documents, nor did he
provide sufficient substantiation of the purported business
travel expenses through contemporaneous records or otherwise.
Petitioner used his corporations as his personal
pocketbooks, paying both his and his family's personal and living
expenses out of the corporate till. He not only failed to
include these amounts in his gross income, but he also deducted
many of the same amounts from the income of his corporations. We
do not believe petitioner's actions and omissions were
reasonable. In light of his actions and omissions, and with no
argument or evidence presented by petitioner to the contrary, we
sustain respondent on this issue.
(c) Section 6655--GAPS and JJM Estimated Tax Additions
The final issue is whether GAPS and JJM are liable for the
addition to tax under section 6655 for failure to pay estimated
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