- 34 - 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 estimatedPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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