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With respect to petitioner's disallowed Villa del Mar
business deductions for 1992, 1993, and 1995 legal expenses,
petitioner failed to show he supplied his accountants with
complete and accurate information concerning these claimed
deductions. To demonstrate reasonable cause, a taxpayer must
show that he relied in good faith on a qualified adviser after
full disclosure of all necessary and relevant information. See
Jackson v. Commissioner, 86 T.C. 492, 539-540 (1986), affd. 864
F.2d 1521 (10th Cir. 1989). However, in the instant case,
petitioner failed to elaborate as to what exactly he had told or
had not told his accountants concerning the specific purposes of
these legal expenses. See Stark v. Commissioner, T.C. Memo.
1999-1; cf. Test v. Commissioner, T.C. Memo. 2000-362.
With respect to the disallowed Amazona loss deduction of
$28,859, we are not satisfied petitioner had disclosed all the
relevant facts to his accountants. The bank statements on
Amazona’s account reflect that many of the claimed expenses were
likely incurred in 1991, rather than in 1992. Moreover, many of
the claimed expenses (other than the $794.08 in legal expenses)
were later shown not to have been expended for the purposes
stated on Amazona’s and petitioner’s 1992 returns.
With respect to the Roadmaster Leasing partnership losses of
$5,000 for 1992 and $3,558 for 1994, petitioner testified that he
had paid Mr. Candelario (an accountant) $1,000 in 1993 to provide
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