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Ma-Tran Corp. v. Commissioner, 70 T.C. 158, 173 (1978).
Petitioner contends that he is not liable for the accuracy-
related penalty under section 6662(a) because he relied on Mr.
Sutton, who prepared the joint returns of petitioner and Ms.
Brodsky for 1991 and 1992, and on Mr. DiBernardo, who prepared
their joint return for 1993, to whom he provided all of his
financial information. On the instant record, we reject that
contention. On that record, we find that petitioner has failed
to carry his burden of establishing (1) that he provided correct
and complete information to Mr. Sutton and Mr. DiBernardo in
connection with their return preparation on his behalf and
(2) that any item incorrectly omitted, claimed, or reported in
the joint returns for the years at issue was the result of the
error of one of those return preparers. On the instant record,
we also find that petitioner failed to maintain adequate books
and records and to substantiate properly items claimed on the
joint returns for the years at issue.
On the record before us, we find that petitioner has failed
to carry his burden of showing (1) that the underpayment for each
of the years at issue was not due to negligence or disregard of
rules or regulations and (2) that he acted with reasonable cause
and in good faith with respect to the underpayment for each of
those years. On that record, we find that petitioner has failed
to carry his burden of establishing that he is not liable for
each of the years at issue for the accuracy-related penalty under
section 6662(a).
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