- 21 - petitioners are not liable for the penalty pursuant to section 6662(a) for the years 1993 and 1994. With respect to 1995, petitioner asserts that his reliance on J.E. & Assoc. was reasonable. We disagree. Petitioner asserted that the figures reflected on petitioners’ 1995 tax return were “blown out of proportion”. Petitioner testified that although it was “possible” to have gross receipts and expenses in amounts as reflected on petitioners’ 1993 and 1994 returns, with respect to petitioners’ 1995 return, “jumping up another half a million dollars in one more year, it’s impossible.” Additionally, petitioner testified that he never examined the 1995 tax return until recently. The 1995 return was signed by petitioners on November 18, 1996. Petitioner stated that his attorney was “handling most of it until him [his attorney] and I parted ways”. The colloquy set forth below exemplifies petitioner’s testimony on this matter: THE COURT: * * * When you saw the return-–I know that you have an accountant prepare–- MR. PRATT: I never saw this return until just recently. THE COURT: Why not? MR. PRATT: My attorney was handling most of it until him and I parted ways. THE COURT: Yes, but we’re talking about ‘95. MR. PRATT: Yes.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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