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taxpayer's effort to assess his proper tax liability.
Stubblefield v. Commissioner, T.C. Memo. 1996-537; sec. 1.6664-
4(b)(1), Income Tax Regs.
Taxpayers are required to keep records sufficient to
establish the amount of deductions or other matters required to
be shown on their returns. Sec. 6001; sec. 1.6001-1(a), Income
Tax Regs. Failure to maintain adequate records may constitute
negligence. Schroeder v. Commissioner, 40 T.C. 30, 34 (1963).
Generally the duty of filing an accurate return cannot be
avoided by placing responsibility upon a third party. Metra Chem
Corp. v. Commissioner, 88 T.C. 654, 662 (1987); Fortner v.
Commissioner, T.C. Memo. 1993-195. Reliance on the advice of a
qualified adviser may demonstrate reasonable cause and good
faith; however, the evidence must show that the taxpayer
contacted a competent tax adviser and provided the adviser with
all the necessary and relevant information. See Jackson v.
Commissioner, 86 T.C. 492, 539-540 (1986), affd. 864 F.2d 1521
(10th Cir. 1989); sec. 1.6664-4(b)(1), Income Tax Regs.
Petitioner's reliance on Robinson v. Commissioner, 51 T.C.
520 (1968), affd. in part and vacated in part per curiam 422 F.2d
873 (9th Cir. 1970), and other similar cases is misplaced. In
Robinson, this Court sustained respondent's disallowance of
various expenses for failure to comply with section 274 and the
accompanying regulations but, nonetheless, held that the taxpayer
was not liable for the addition to tax for negligence under
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