- 21 - also have forgotten to record other sales of unknown amounts. Petitioner’s testimony reveals that he was aware that invoices may not have been prepared for a number of larger items sold by FAP. Petitioner used the understated amount reflected by the invoices to prepare summary sheets which he then provided to the return preparer. Petitioner failed to inform the return preparer that certain sales were omitted. In addition, petitioner did not always deposit the proceeds from FAP’s sales into a bank account; therefore, there was no record of some portion of the sales. Petitioners also contend that these unrecorded and unreported sales were of minor consequence. However, respondent’s reconstruction of petitioners’ income reflects relatively sizable amounts of omitted income. As to the remaining items making up the deficiency, apart from the capital gain item, petitioners did not make any argument as to why respondent’s determination was in error or that their return position was reasonable. Therefore, we find petitioners liable for the accuracy-related penalties on the resulting income tax deficiencies. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Last modified: May 25, 2011