Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia & Carol Ann Gorveia, a.k.a. Carol Gouveia, et al. - Page 52

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          competent tax professionals, and the taxpayer’s efforts to assess           
          his proper tax liability.  Sec. 1.6664-4(b)(1), Income Tax Regs.            
               Petitioner testified that before forming the trusts, he                
          spoke with his former tax return preparer, who was not familiar             
          with trusts, met with a company called the Independent Trust                
          Consultants, and “read as much material as [he] could from                  
          libraries.”  Petitioner also testified that he hired his tax                
          return preparer because she was “familiar with estates and trusts           
          [and] Form 1041”, but he did not ascertain her level of                     
          education.  The Gouveias introduced no other evidence of their              
          knowledge or degree of experience in tax matters.  Moreover,                
          petitioner’s testimony does not establish that anyone with whom             
          the Gouveias consulted provided any advice upon which they relied           
          or that the Gouveias made any sincere effort to determine whether           
          the trust arrangement would be respected for Federal income tax             
          purposes.  Because the Gouveias have not demonstrated that they             
          acted in good faith and that there was reasonable cause for the             
          underpayment, we sustain respondent’s determination that the                
          Gouveias are liable for the accuracy-related penalty under                  
          section 6662(a) for 1995, 1996, 1997, and 1998 on any                       
          underpayment of income tax attributable to unreported income from           
          the Pago and McKenzie Trusts.                                               









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