Bennett Geiger - Page 18

                                       - 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