32
Perkins believed there was no reason to question the accuracy of
those summaries. We disagree.
As discussed at par. B-1, above, petitioners offered no
evidence showing what information or documentation they provided
to Perkins concerning their IBM payments, wages from A&P, or
interest income, and they did not explain why they did not report
various income items for 1990 and 1991 including the income from
International. We hold that petitioners are liable for the
accuracy-related penalty for 1990 and 1991 because they have not
shown that they reasonably relied on Perkins.
Decision will be entered
under Rule 155.
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