- 17 - person under like circumstances. See Neely v. Commissioner, 85 T.C. 934, 947 (1985). In the petition, petitioner assigns error to respondent’s determination of section 6662 penalties with respect to the cash transactions. However, petitioner does not aver any specific facts in support of her assignment of error. On brief, petitioner claims that she relied on her accountant properly to prepare her Federal income tax returns for 1992 and 1993. A taxpayer acts reasonably when she provides her accountant or attorney with all relevant information necessary to prepare her tax return, and she relies, in good faith, on the advice of her attorney or accountant regarding a matter of substantive tax law. See Jaques v. Commissioner, T.C. Memo. 1989-673, affd. 935 F.2d 104 (6th Cir. 1991); see also United States v. Boyle, 469 U.S. 241, 251 (1985). The taxpayer, however, bears the ultimate responsibility for the correctness of her income tax return, and good faith reliance on professional advice is not a substitute for compliance with an unambiguous statute that requires no special training or effort to understand and apply. See United States v. Boyle, supra at 251-252. Accordingly, where the taxpayer delegates the preparation of her income tax return to a tax return preparer, the taxpayer has a duty to provide the tax return preparer with all relevant information necessary to prepare the return, see Pessin v. Commissioner, 59 T.C. 473, 489Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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