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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.
Background
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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Last modified: May 25, 2011