- 6 - $22,009 was deducted on the return, and depreciation of $1,645.50 was allowed as a deduction based on the audit. Wages of $236,903 are shown on the return; payroll of $231,793.87 is listed on the reconstruction. Rent of $160,306 was reported; rent of $141,297.03 was included in the adjusted expense amounts. Only advertising expenses of $3,600 correspond precisely in the two computations. OPINION We must decide whether petitioner is liable for either the delinquency addition to tax or the accuracy-related penalty in connection with the filing and content of his 1995 Federal income tax return, or for both. Petitioner contends that the stipulations entered by the parties constitute a full settlement of all issues in exchange for the payment of an additional tax of $17,823 for 1995. To determine supplemental sums under sections 6651 and 6662 is therefore, in petitioner’s view, a violation of the settlement agreement. Petitioner also asserts that his reliance on a certified public accountant to prepare and file his return establishes reasonable cause excusing him from responsibility for any untimeliness or inaccuracies. Conversely, respondent argues that petitioner’s alleged reliance on his tax preparer fails to satisfy the standard of reasonable cause necessary to relieve petitioner from either thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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