Bradley D. Becnel - Page 10

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          had sufficient information to determine his precise tax liability           
          for 2002, he did not attempt to estimate the omitted income he              
          received during the year at issue.  Petitioner could have                   
          approximated his investment income based on past annual reports             
          or previously filed returns.  Knowing that the accounts that                
          produced the omitted income existed, petitioner could have                  
          contacted the businesses where these accounts were located and              
          requested that copies of the Forms 1099-B and 1099-DIV or                   
          duplicates thereof be sent to him.  Even if petitioner were                 
          unable to obtain any information regarding the omitted income               
          prior to filing his income tax return for 2002, he could have               
          attached a statement to the return explaining the relevant facts            
          and circumstances and indicating that an amended return would               
          later be filed.  Instead, petitioner relied upon his father to              
          assess his tax liability and ignored the matter until respondent            
          issued the notice of deficiency.                                            
               While the Court sympathizes with petitioner and understands            
          the difficulties, financial and otherwise, he encountered from              
          his bacterial infection and Mr. Vicknair’s death, those                     

               3(...continued)                                                        
          brokers who managed the accounts.  These brokers provided Mr.               
          Becnel and his family with annual updates concerning their                  
          accounts’ performances.  Because most people monitor their                  
          investments, the Court inquired as to why petitioner’s financial            
          affairs were not so monitored.  Mr. Becnel addressed this concern           
          by testifying:  “Well, when you do the tobacco settlement, and              
          you settle the case for $287 billion, and you get paid four times           
          a year, money is irrelevant.”                                               




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