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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.
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