Eric A. and Jane C. Lanigan - Page 12

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            of the deficiencies.  However, he asserts that he cooperated                                  
            fully with respondent in the preparation of the returns, that he                              
            took in the records that he had at that time, and that he made                                
            payment of the taxes as computed by the IRS representative by the                             
            date she specified.                                                                           
                  Generally, the taxpayer cannot avoid the duty of filing                                 
            accurate returns by placing responsibility on a tax return                                    
            preparer.  Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662                                 
            (1987).  Reliance on the advice of a professional does not                                    
            necessarily demonstrate reasonable cause and good faith, unless                               
            under all the facts and circumstances, such reliance was                                      
            reasonable and the taxpayer acted in good faith.  Sec. 1.6664-                                
            4(b)(1), Income Tax Regs.  Where the taxpayer claims reliance on                              
            an accountant who prepared the taxpayer's return, the taxpayer                                
            must establish that the correct information was provided to the                               
            accountant and that the item incorrectly claimed or reported in                               
            the return was the result of the accountant's error.  Ma-Tran                                 
            Corp. v. Commissioner, 70 T.C. 158, 173 (1978); Enoch v.                                      
            Commissioner, 57 T.C. 781, 803 (1972).                                                        
                  Here, the tax preparer was not petitioners' accountant but                              
            an IRS representative.  He reasonably relied on her expertise as                              
            a tax preparer.  Petitioner believed from the statements made by                              
            the IRS representative that the IRS records contained his income                              
            information.  However, he took no steps to verify those records.                              






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