Yousef Rouzmehr - Page 5

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          part 43 T.C. 168 (1964) and T.C. Memo. 1964-299; sec. 1.6662-3(b), Income Tax
          Regs.                                                                       
               Petitioner has the burden of proving that respondent's determination   
          with regard to negligence is erroneous.  Marcello v. Commissioner, supra at 
          506; Murphy v. Commissioner, 103 T.C. 111 (1994).                           
               A taxpayer cannot avoid his duty to file accurate returns simply by    
          shifting responsibility to his agents.  Pritchett v. Commissioner, 63 T.C.  
          149, 159 (1974).  The ultimate responsibility for a correct return lies with
          the taxpayer, who must furnish the necessary information to his agent who   
          prepared the return.  Enoch v. Commissioner, 57 T.C. 781 (1972). Petitioner 
          has been in this country for more than 10 years, attended college here, and is
          doing business here.  He has a responsibility and a duty to comply with the 
          income tax laws and to familiarize himself with them.  We thus find and hold
          that petitioner is liable for the penalty for negligence.                   
               To reflect the foregoing,                                              


          Decision will be entered                                                    
          under Rule l55.                                                             
























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