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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.
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