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on Mr. Zahar’s advice in claiming deductions for mortgage interest
and property taxes in 1995.
Gabriel testified that he provided Mr. Zahar with information
about his income and told him that he and his brother were paying
for “the house and the mortgage, and all the taxes and all the
expenses. Food, drink, electricity.” Mr. Zahar testified that he
believed Gabriel and Morhaf were supporting the Mahmoud Daya
family during the years at issue and that Fuad provided additional
money to the family from “time to time”. There is no evidence,
however, that petitioners informed Mr. Zahar of the extent of
Fuad’s contributions to the family. Yet out of a total of
$32,531.88 deposited into the household account in 1995, Fuad
contributed at least $18,500. Without such information, Mr. Zahar
could not have determined petitioners’ entitlement to the
deductions at issue and to head of household filing status.
Under these circumstances, petitioners have not shown they
had reasonable cause for their underpayment of taxes or acted in
good faith. Accordingly, we uphold respondent’s determinations
that petitioners are liable for additions to tax under section
6662(a).
We have considered all other arguments advanced by
petitioners, and to the extent not discussed above, have found
those arguments to be irrelevant or without merit.
To reflect the foregoing,
Decisions will be entered
for respondent.
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