Victor M. Bello - Page 24




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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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