- 63 - to treat LFI and BAC as businesses under section 162 and to ignore his concerns regarding the possible application of section 183 without a healthy degree of skepticism and some meaningful professional analysis falls short of proof establishing that petitioner reasonably relied on the informed and studied advice of a competent tax professional. We also have considerable doubt whether petitioner acted in good faith when he signed his tax returns for the years at issue. Petitioner, an experienced businessman, knew or certainly should have known that he and his family and invited guests used Granot Loma and BAC’s aircraft primarily for personal relaxation and entertainment. Possessed of such knowledge, petitioner cannot credibly claim that he signed his tax returns in good faith. Under the circumstances, petitioner’s attempt to avoid liability for the additions to tax and penalties by claiming he did not know any better is ludicrous. Because petitioner has failed to prove that he was not negligent under sections 6653(a) and 6662 or that he is entitled to relief under section 6664(c), we reject petitioner’s arguments that he should be relieved of the section 6653 addition to tax and the section 6662 penalties in these consolidated cases.Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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