- 29 - of income on a return has been found to be indicative of negligence. Anders v. Commissioner, 68 T.C. 474, 493 (1977). Individual petitioners knew that they received interest income from the Standard Chartered account. In addition, the Standard Chartered account had a substantial balance and earned a significant amount of interest. However, petitioners did not inform their accountant about the interest income or the existence of the account. The bank statements from the Standard Chartered account were addressed to both petitioner husband and Lily Chan. For a time, the statements were sent to the Eastimpex office. During the years in issue, the statements were mailed to an address in Hong Kong. Petitioner husband gave inconsistent testimony about where Lily was living during the years in issue. Individual petitioners maintain that they reasonably relied on the Eastimpex bookkeepers to provide tax information to their tax return preparer because they received mail regarding personal finances at Eastimpex. However, individual petitioners admitted that they received mail regarding interest income at their personal address as well as at Eastimpex's offices. Thus, we reject petitioners' contention that their failure to report the interest income was a reasonable oversight. We find that individual petitioners are negligent and lack substantial authority with regard to their failure to report interest income from the Standard Chartered account and are liable for the additions to tax.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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