Floyd L. Garrett and Dorothy G. Garrett - Page 28

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          returns cannot be avoided by placing the responsibility on a tax            
          return preparer.  Metra Chem Corp. v. Commissioner, 88 T.C. 654,            
          662 (1987).  However, reliance on a qualified adviser may                   
          demonstrate reasonable cause and good faith if the evidence shows           
          that the taxpayer contacted a competent tax adviser and provided            
          the adviser with all necessary and relevant information.  Jackson           
          v. Commissioner, 86 T.C. 492, 539-540 (1986), affd. 864 F.2d 1521           
          (10th Cir. 1989); Daugherty v. Commissioner, 78 T.C. 623, 641               
          (1982); Magill v. Commissioner, 70 T.C. 465, 479 (1978), affd.              
          651 F.2d 1233 (6th Cir. 1981); Pessin v. Commissioner, 59 T.C.              
          473, 489 (1972).  In addition, even if petitioners can establish            
          the above requirements, they still have a duty at least to read             
          and make a cursory review of the return and make sure all income            
          items are included.  Metra Chem Corp. v. Commissioner, supra at             
          662; Magill v. Commissioner, supra at 479-480.                              
               Petitioners failed to establish that they supplied Mr.                 
          Knutzen with complete and accurate information.  Taxpayers who              
          control the affairs of a corporation cannot establish that they             
          provided correct information to their return preparer if the                
          corporate records they provide incorrectly reflect that alleged             
          business expenses did not benefit the individual.  Magill v.                
          Commissioner, supra at 479.  Mr. Garrett either failed to                   
          disclose or concealed from Mr. Knutzen the true extent of                   
          personal expenditures made with the corporate funds of FGI and              
          TTI by providing canceled checks, check stubs, and receipts that            




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