- 14 - in preparing his 1991 return. Such reliance, petitioner claims, is evidence that he acted with reasonable cause and in good faith. Reliance on "professional" advice will constitute reasonable cause only if the taxpayer acted in good faith and made full disclosure of all relevant facts to the adviser. See Paula Constr. Co. v. Commissioner, 58 T.C. 1055, 1061 (1972), affd. without published opinion 474 F.2d 1345 (5th Cir. 1973). Petitioner admitted at trial that, when he called the hotline, he did not explain that the equipment was being leased or that no income was being reported from the activity in 1991. Petitioner did not make full disclosure so that his alleged reliance on the hotline is reasonable cause. Petitioner failed to keep adequate records to substantiate his entitlement to deductions that he claimed. Sec. 6001; Crocker v. Commissioner, 92 T.C. 899, 912 (1989); sec. 1.6001-1, Income Tax Regs. Petitioner's whole case is based on inconsistencies and improbabilities and lacks credibility. Petitioner has not established reasonable cause or good faith reliance to excuse him from the penalty for negligence or intentional disregard of rules or regulations. To reflect the foregoing and a concession of petitioner, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
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