Medieval Attractions N.V - Page 53

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          notified by C&L's Orlando office that a reporting entity had to             
          report each transaction with a related party on a Form 5472,                
          which should be filed with their tax returns.  The Federal tax              
          forms specifically requested information about related parties.             
          Petitioners failed to disclose all of the required information              
          and to file the appropriate Forms 5472.  Taxpayers cannot hide              
          behind a claim that they were not aware of the need to provide              
          the information because they did not read their returns.  The               
          voluntary failure to read a return and blind reliance on another            
          for the accuracy of a return are not sufficient bases to avoid              
          liability for negligence additions to tax.  Bailey v.                       
          Commissioner, 21 T.C. 678, 687 (1954).  Additionally, petitioners           
          continued to withhold related-party information.  During the IRS            
          audit, Santandreu provided a document to the IRS that stated that           
          he did not know the shareholders of Dapy, Manver, Lince, and                
          Promidux.                                                                   
               Petitioners were owned and operated by sophisticated                   
          businessmen.  They did not have to have knowledge of U.S. tax               
          laws or any special training to understand the significance of              
          creating and backdating documents.  A central figure with respect           
          to the backdated documents, Onate, was not called by petitioners            
          to testify, notwithstanding the Court's expressed interest in               
          having him called as a witness.  Respondent was unable to                   
          effectuate service on Onate because Onate was out of the country.           
          Petitioners also did not call A. Gelabert or Segui to testify.              




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