(petitioner owned two S corporations and used tax preparer to prepare corporate returns; tax information kept on QuickBooks by petitioner which preparer had access to, but for years in issue petitioner's office being renovated and hard-copy not available; preparer would not prepare returns without source documents; preparer ultimately prepared 1040s but not the 1120s, and noted on 1040s that pass-through income from 1120s not included but would be furnished when available; Form 8275 not attached to either 1040 for years at issue; consequently, Form 1120s late; statement included on return that K-1 income not included because K-1s not available and that petitioner's personal return would be amended as soon as K-1s available; omitted income exceeded $130,000; IRS assessed penalties based on lack of authority for underpayment and since no Form 8275 filed reasonable basis standard inapplicable; penalties affirmed by Tax Court; preparer should have estimated the K-1 income, Filed Form 8275 and then amended return).