Kupan, a famous forensic pathologist, failed to report income from the sale of his mansion on his

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Kupan, a famous forensic pathologist, failed to report income from the sale of his mansion on his tax return. His gain on sale exceeded $1.7 million. He also sold stock at a $400,000 gain and did not report that gain either.
In a criminal prosecution against Kupan for tax fraud, Kupan blamed his accountant Rachel for the omission, claiming that Rachel knew that the pathologist was a "poor record-keeper." Kupan admitted that he read the tax return prepared by Rachel and signed it. Will Kupan's defense of shifting responsibility to Rachel in this criminal prosecution be successful?
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