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Federal income tax returns.47 Petitioner did not provide any
documentation or testimony indicating why his 1990 and 1991
Federal income tax returns should be treated other than as he
originally reported them. Petitioner has not met his burden and
established that correcting entries should be made as he asserts.
VIII. Issue 8. Accuracy-Related Penalty
A. Background
Petitioner did not prepare his personal income tax returns
or those of the corporations and partnerships in which he held an
interest with respect to the years in issue. Petitioner’s
employee, Ms. Fox, prepared his tax returns for the years 1990
through 1993. In preparing the returns, Ms. Fox had assistance
from an outside accountant in each year.
In preparing the returns, Ms. Fox had access to petitioner’s
business files in the Brevard County office. Petitioner was not
customarily in the Brevard County office when Ms. Fox was
preparing the returns.
Ms. Fox collected the information to be placed on the
return, and petitioner was available to speak to her and the
assisting accountant in the event they had questions concerning
an item of income or a transaction.
47This issue does not relate to an adjustment made in the
notice of deficiency. Instead, it relates to a claim that
petitioner initially made in his petition.
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