Dennis L. and Sharon E. Hayden - Page 12

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          insignificant figures, and we find it hard to believe that, when             
          preparing or supervising the preparation of the return,                      
          petitioner would not have questioned the deduction of this size.             
          This is particularly true because petitioner was aware that his              
          Federal income taxes had been paid from the bank account used for            
          the accounting practice, a practice which in and of itself is                
          suspect.  Either he closed his eyes to the facts, or he simply               
          did not properly supervise the preparation of the return.                    
          Petitioner has not established that he was not negligent.                    
          Therefore, respondent's determination as to the accuracy-related             
          penalty under section 6662(a) is sustained.                                  
                                                   Decision will be entered            
                                              for respondent.                          

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