- 24 - 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 providePage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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