- 17 - tax liability for 1986.12 Under these circumstances, petitioner cannot insulate himself from the negligent omission of $4 million of taxable income from the return. Accordingly, we hold that petitioner is liable for the additions to tax for negligence for 1986. Decision will be entered under Rule 155. 12The $2 million difference is attributable to the fact that petitioner’s adjusted gross income and tax liability shown on the original return was underreported by approximately 40 percent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
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