- 9 - for the Second Circuit. United States v. Bilzerian, 926 F.2d 1285 (2d Cir. 1991). On October 21, 1991, respondent issued separate notices of deficiency to petitioner and Mr. Bilzerian for the taxable year 1986. In the notices of deficiency, respondent determined that petitioner and Mr. Bilzerian were liable for additions to tax for negligence due to the omission from their originally filed 1986 return of the approximately $4 million of taxable income from gains related to the purchase and sale of Hammermill stock. Petitioner filed a petition to this Court seeking a redetermination. In 1992, Mr. Bilzerian sued Mr. Norris for malpractice for the omission of the $4 million of taxable income from the Bilzerians’ originally filed 1986 return. In connection with the malpractice lawsuit, Mr. Norris denied any liability with respect to the preparation of petitioner and Mr. Bilzerian’s 1986 tax return. OPINION In Bilzerian v. Commissioner, T.C. Memo. 2001-187, we sustained respondent’s determination that Mr. Bilzerian was liable for the additions to tax for negligence under section 6653(a)(1)(A) and (B) for 1986. We found that Mr. Bilzerian failed to establish that he reasonably relied on his returnPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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