Walter Joseph Hess - Page 3

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          decision are whether petitioner is liable for the section                   
          6651(a)(1) addition to tax and 6662(a) accuracy-related penalty             
          relating to his 2002 Federal income tax return.                             
               During 2002, petitioner was the majority owner of Clinton              
          House Associates partnership (the partnership).  In addition,               
          petitioner’s father, William Hess, was a partner.  On April 1,              
          2003, William Hess died.                                                    
               On August 13, 2003, petitioner filed a Form 2688,                      
          Application for Additional Extension of Time to File U.S.                   
          Individual Income Tax Return, relating to 2002 and was granted an           
          extension until October 15, 2003.  Petitioner’s accountant                  
          prepared petitioner’s 2002 Form 1040, U.S. Individual Income Tax            
          Return, and a Schedule K-1, Partner’s Share of Income,                      
          Deductions, Credits, etc., relating to the partnership.  The                
          accountant, however, omitted, from the Form 1040, petitioner’s              
          allocable share of partnership income as reported on the Schedule           
          K-1.  Petitioner signed, but did not review, the Form 1040 before           
          mailing it to respondent.  Petitioner’s return was received by              
          respondent on October 23, 2003.                                             
               On October 25, 2004, respondent issued petitioner a                    
          statutory notice of deficiency relating to 2002 in which                    
          respondent determined that petitioner failed to report interest,            

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