- 19 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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