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66 T.C. 272, 283 (1976). This is true even where the advice
relied upon was erroneous. Brown v. Commissioner, 47 T.C. 399,
410 (1967), affd. 398 F.2d 832 (6th Cir. 1968). However,
petitioner did not testify that she relied on her accountant.
Moreover, petitioner bears the burden of proving that she at
least supplied the accountant with the necessary information and
that the incorrect return resulted from the preparer's mistakes.
Pessin v. Commissioner, 59 T.C. 473, 489 (1972).
Petitioner's accountant, Mr. Maynard, testified that he
would have reviewed the prior returns and any information that
was in the file when he first started preparing petitioner's
returns in 1984, but he could not recall what information was in
petitioner's file. We find that petitioner has not met her
burden of showing that she was not negligent. Accordingly, we
sustain respondent's determination that petitioner is liable for
the accuracy-related penalty pursuant to section 6662(a).
Decision will be entered
under Rule 155.
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