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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.
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