Stanley M. Kurzet and Anne L. Kurzet - Page 54

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            returns are reasonably explained by the factually oriented                                
            nature of each of the issues in this case, by the factually                               
            complicated nature of the many business, investment, and                                  
            personal activities in which petitioners were involved, by the                            
            consuming manner in which petitioners undertook each of the                               
            activities in which they became involved, by the nature and                               
            volume of the many categories of expenses incurred by                                     
            petitioners each year, by the nature of the books and records                             
            which petitioners innocently but amateurishly developed and                               
            used, by the failure of petitioners’ accountants and tax return                           
            preparers to prepare diligently the returns in question, and by                           
            the unfortunate relationship that developed between petitioners'                          
            and respondent's representatives throughout the course of this                            
            dispute.                                                                                  
                  No one of the above factors is determinative.  But we                               
            believe that, on the unique facts and circumstances of this                               
            case, imposition of any of the asserted additions to tax would                            
            be inappropriate.  We so hold.                                                            
                                                                                                     
                                                      Decision will be                                
                                                entered under Rule 155.                               












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