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liability for the addition to tax for negligence merely by
shifting the responsibility to a tax professional. Enoch v.
Commissioner, 57 T.C. 781, 802-803 (1972). Reliance on an expert
is not an absolute defense but is a factor to be considered.
Freytag v. Commissioner, supra at 888. A taxpayer's reliance
must be in good faith and demonstrably reasonable. Ewing v.
Commissioner, 91 T.C. 396, 423 (1988), affd. without published
opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner,
supra at 888-889. In such a case, a taxpayer will be entitled to
rely upon an expert's advice, even if the advice should prove to
be erroneous. Jackson v. Commissioner, 86 T.C. 492, 539 (1986),
affd. on other issues 864 F.2d 1521 (10th Cir. 1989); Brown v.
Commissioner, 47 T.C. 399, 410 (1967), affd. 398 F.2d 832 (6th
Cir. 1968).
The ultimate responsibility for a correct return lies with
the taxpayer, who must furnish the necessary information to the
agent who prepared the return. Enoch v. Commissioner, supra at
802. In other words, reliance upon expert advice will not
exculpate a taxpayer who supplies the return preparer with
incomplete or inaccurate information. Lester Lumber Co. v.
Commissioner, 14 T.C. 255, 263 (1950).
Turning to the facts of the instant cases, we note that LTD
did not file any income tax returns or withholding tax returns
and that INC did not file any withholding tax returns. We have
held that LTD is liable for corporate income tax for taxable
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