- 3 - (5) Whether petitioners are liable for an addition to tax under section 6661(a) for a substantial understatement of tax for taxable year 1988. We hold that they are. Background Petitioners resided in New Orleans, Louisiana, at the time the petition was filed. Petitioners timely filed their joint Federal income tax returns for the years at issue. References to petitioner in the singular are to Emmett I. Sindik. Petitioner is the sole proprietor of an import-export business. Petitioner has been in the business for more than 25 years acting as the middleman between U.S. and foreign importers and exporters handling U.S. Customs duties, ocean freight fees, and trucking fees. Petitioner essentially completes the paperwork involved and charges a fee to his clients for this service; he has no monetary interest in the cargo other than his fee. Petitioner’s clients write checks payable to petitioner as a customs broker for customs duties and various other fees. Petitioner deposits these checks into his bank account and subsequently issues checks to the appropriate agencies. Mrs. Sindik did not participate in petitioner’s business or in the preparation of their returns. Petitioner failed to maintain complete and accurate records of his income-producing activities and failed to produce complete and accurate records to respondent in connection with thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011