- 18 - claiming zero tax liability for the current year and refunds for several prior years. Petitioner did not consult an accountant to prepare the loss but rather relied on his then wife, Ms. White, who has no experience in bookkeeping. Ms. White’s analysis yielded a total of $1,801,213. However, once consulted, petitioner’s accountant quickly reduced that amount to $704,500. Accordingly, petitioner does not qualify for the reasonable cause exception in section 6664(c)(1), and we hold that petitioner is liable for the penalty pursuant to section 6662 for a substantial understatement of income tax. We have considered all of petitioner’s contentions, and, to the extent they are not discussed herein, they are moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011