- 27 - With respect to 1991, the year in issue in this case, petitioner claimed that he incurred $55,880 in losses from the Hoyt partnerships. Petitioner did not know how these losses were derived; he knew only that the Hoyt organization had reported the amounts on the Schedules K-1 and on his tax return. Petitioner claimed these losses despite the fact that respondent had been warning petitioner, at least since May 1988, that there were potential problems with the tax claims being made on both the partnership returns and on petitioner’s returns. Prior to signing his 1991 return, petitioner had received at least 12 separate letters from respondent alerting petitioner to suspected problems or alerting petitioner to reviews that had been commenced with respect to various Hoyt partnerships in which he was involved. Despite these letters, petitioner did not further investigate the partnership losses, such as by consulting an independent tax adviser, before claiming the losses as deductions on his 1991 return. We conclude that petitioner was negligent in 1991 in claiming the Hoyt partnership loss at issue in this case; namely, the $16,720 loss from DSBS 87-C. IV. Alleged Defenses to the Accuracy-Related Penalty Section 6664(c)(1) provides that the section 6662(a) accuracy-related penalty is not imposed “with respect to any portion of an underpayment if it is shown that there was a reasonable cause for such portion and that the taxpayer acted inPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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