- 20 - required to be shown on the return was $12,338. Therefore, petitioner understated his income tax in an amount greater than $5,000 or 10-percent of the tax required to be shown on his return. Petitioner did not present any evidence or make any showing as to why respondent’s penalty determination is in error. Petitioner contends that he is not liable for the accuracy- related penalty because he had a reasonable basis for the tax items at issue and because he relied on the advice of a representative of Fidelity Investments. Given petitioner’s legal education and experience, petitioner did not have a reasonable basis for the tax items at issue, especially in the absence of substantiating records. Moreover, petitioner’s purported reliance on a financial representative was not reasonable nor prudent. See sec. 1.6662-4(c), Income Tax Regs. The facts and circumstances of this case support the imposition of an accuracy-related penalty under section 6662(a) and (b)(2). Accordingly, we sustain respondent’s determination on this issue. E. Conclusion We have considered all of the other arguments made by the parties, and, to the extent that we have not specifically addressed them, we conclude they are without merit.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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