- 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, 489
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