- 286 - support of numerous other losses claimed. The failure to document such large losses constitutes negligence. For the years 1979, 1980, and 1981 petitioner claimed amounts of interest paid to the Mirhosseini family. He was unable to show that a significant portion of the interest expense claimed was actually paid to the Mirhosseini family or that debtor/creditor relationships existed between him and the Mirhosseini family. For 1977 and 1978 petitioner had substantial amounts of unreported income. Although he claimed the income belonged to Diesel Power, it was under his dominion and control. It was deposited to his bank account pursuant to directions he gave the payors, and he performed the services for which the income was paid. Furthermore, the manner in which the income was treated on CTC's books and records was erroneous because it reflected the unreported amounts as being the income of Diesel Power. His return preparers relied on the books in preparing his tax returns. The information relied upon by the return preparers was not accurate, which is a further indication that petitioner was negligent. Accordingly, we sustain respondent's determinations with respect to the additions to tax for negligence for each of the years 1977 through 1981.Page: Previous 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 286 287 Next
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