Leo and Alla Goldberg - Page 63

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          respondent's determination that petitioners are liable for the              
          accuracy-related penalty for 1990 and 1991 will be sustained.               
               Mrs. Goldberg is not excused from the negligence addition to           
          tax and penalties for 1990 and 1991 solely because of her failure           
          to read petitioners' returns or her reliance on petitioner for              
          the accuracy of the returns.  Failure to read a return and blind            
          reliance on another for the accuracy of a return are not                    
          sufficient bases to avoid liability for negligence.  See Bollaci            
          v. Commissioner, T.C. Memo. 1991-108 (citing Bagur v.                       
          Commissioner, 66 T.C. 817, 823-824 (1976), remanded on other                
          grounds 603 F.2d 491 (5th Cir. 1979)).  Taxpayers have a duty to            
          read a return and to make sure all items are included.  Magill v.           
          Commissioner, 70 T.C. 465, 479-480 (1978), affd. 651 F.2d 1233              
          (6th Cir. 1981) (citing Bailey v. Commissioner, 21 T.C. 678, 687            
          (1954)).                                                                    
               To reflect the foregoing and the concessions by the parties,           
                                                  Decision will be entered            
                                             under Rule 155.                          
















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