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attributable to the difference between the property's cost basis
and the amount received on its disposition is evidence of
negligence. See Montoya v. Commissioner, T.C. Memo. 1999-269.
Petitioner testified that another reason he did not file an
amended return for 1992 is that he never received a Schedule K-1
informing him of his portion of the gain. Petitioner testified
that he received Schedules K-1 for all the years that he was a
partner in Dasco (including the 1995 year), except the Schedule
K-1 for the amended return year. Furthermore, petitioner
testified that if he had received a Schedule K-1 informing him of
his share of the gain, he would have reported the income on an
amended return.
The nonreceipt of tax documents does not excuse taxpayers
from their duty to report income. See, e.g., Scott v.
Commissioner, T.C. Memo. 1997-507 (nonreceipt of Schedule K-1 and
Form 1099); Dennis v. Commissioner, T.C. Memo. 1997-275
(nonreceipt of Form 1099); Healy v. Commissioner, T.C. Memo.
1996-260 (nonreceipt of partnership return and Form 1099); Du
Poux v. Commissioner, T.C. Memo. 1994-448 (nonreceipt of Forms W-
2 and 1099-MISC.); Krzepina v. Commissioner, T.C. Memo. 1993-356
(nonreceipt of Schedule K-1).
Moreover, in this case, petitioner was negligent; he did not
do what a reasonable and ordinarily prudent person would do under
the circumstances. Petitioner was a general partner in a two-
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