Lucian T. Baldwin, III - Page 63




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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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