Bobby E. Welch - Page 20

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          through 1990 were not timely filed.  Furthermore, there is                  
          nothing in this record that would even remotely indicate that               
          these failures were due to reasonable cause and not due to                  
          willful neglect.  Therefore, we sustain respondent's                        
          determinations with respect to the additions to tax under section           
          6651(a) for all the years at issue.                                         
               Sections 6653(a) and 6662(a) impose additions to tax and               
          penalties for negligence or disregard of rules or regulations.              
          If any part of the underpayment is due to negligence, under                 
          section 6653(a)(1) the addition to tax is equal to 5 percent of             
          the amount of the underpayment.  Under section 6662(a) the                  
          accuracy-related penalty is equal to 20 percent of the portion of           
          the underpayment due to negligence.  It is clear that petitioner            
          is liable for these additions to tax and accuracy-related                   
          penalties.  Under section 6001 a taxpayer is required to keep               
          records.  As far as we can determine, petitioner kept no records            
          from which his (taxable) income could be determined.  While                 
          petitioner used accounting firms to prepare his returns, as far             
          as Mr. Moore was concerned, petitioner supplied the information             
          in summary fashion.  None of the other return preparers                     
          testified.  With respect to petitioner's gross income, the                  
          information was greatly understated.  Furthermore, with regard to           
          the accuracy-related penalties, the entire underpayment for each            
          of the taxable years 1989 and 1990 was attributable to                      
          negligence.  We sustain respondent's determinations with respect            




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