- 9 - accountant (and return preparer) indicated to him that he had some concern about the returns, that "your taxes are not what they should be", and there was something that did not "measure up". Petitioner discussed this concern with Allan, who assured him that the information on the returns was accurate. Petitioner trusted Allan at the time and made no further inquiries into the matter. Moreover, petitioner's accountant never suggested any specific areas on the returns that were suspect. After the audit of his returns and the reasons for the shortcomings came to light, petitioner dismissed his brother from the business and conceded to the adjustments, except for the issues discussed, portions of which were conceded by respondent and, in one instance, allowed by the Court. On this record, the Court holds that petitioner is not liable for the accuracy-related penalties under section 6662(a) for the 3 years in question. The circumstances described satisfy the Court that there was an honest ignorance of the facts by petitioner regarding Allan's actions in failing to report all the gross receipts of the business. However, the Court sustains petitioner's liability for the accuracy-related penalties for the 3 years in question for that portion of the deficiencies attributable to the unreported interest income.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011