- 5 - 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.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011