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based upon the information provided by petitioner. In that
regard, petitioner has not shown that respondent should have
allowed more based on any record that is available to
petitioner.5
Finally, petitioner argues that his reliance on his
accountant was reasonable. Petitioner contends that he simply
provided the information to his accountant and that the
accountant decided the amount of deductions to which petitioner
was entitled for 1991. Petitioner, however, did not corroborate
this contention, and he failed to present his accountant as a
witness to show that his reliance was reasonable. See Zfass v.
Commissioner, supra at 189.
More importantly, petitioner has admitted that (1) the
preparation of his 1991 return was accomplished in a rush and (2)
he may not have provided his accountant with complete
information. Finally, petitioner was unable to substantiate
almost 40 percent of the business deductions he claimed.
Therefore, petitioner’s claim of reliance was, in the
circumstances of this case, unreasonable. Accordingly, we hold
that petitioner is liable for the accuracy-related negligence
penalty for 1991 on the underpayments attributable to the omitted
5 Petitioner also contended that the State of Maryland had
accepted his amended and 1991 State income tax returns without
change. Petitioner has not shown, however, how that fact (if it
is a fact) would show that petitioner was reasonable in
connection with the filing of his Federal income tax returns.
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