Group Administration Premium Services, Inc., et al. - Page 34

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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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