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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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