Rockwell Banker - Page 5




                                                                                - 5 -- 5 -                                                                                 
                    Petitioner has failed to furnish evidence that would substantiate                                                                                      
                    his claimed miscellaneous itemized deductions.  Petitioner's                                                                                           
                    argument that he relied entirely on Ms. Barber with respect to                                                                                         
                    the amount of the deductions is unavailing.  Such reliance does                                                                                        
                    not establish a lack of negligence.  Petitioner signed the joint                                                                                       
                    1994 Federal income tax return and had a responsibility to check                                                                                       
                    the accuracy of the return.  See Calhoun v. Commissioner, T.C.                                                                                         
                    Memo. 1992-189.  We hold that petitioner is liable for the                                                                                             
                    accuracy-related penalty under section 6662(a).                                                                                                        

                                                                                                    Decision will be entered                                               
                                                                                          under Rule 155.                                                                  




























Page:  Previous  1  2  3  4  5  

Last modified: May 25, 2011