Paul A. Bilzerian - Page 10




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          petitioner supplied Mr. Norris with the necessary information to            
          file an accurate return, he has not shown that the incorrect                
          return was a result of Mr. Norris’s mistake.  Respondent argues             
          that an omission of $4 million in these circumstances is so                 
          substantial that petitioner could not have reasonably relied on             
          the return and should have made further inquiries as to its                 
          accuracy.                                                                   
               The general rule is that taxpayers have a duty to file                 
          complete and accurate tax returns and cannot avoid this duty by             
          placing responsibility with an agent.  United States v. Boyle,              
          469 U.S. 241, 250-251 (1985); Metra Chem Corp. v. Commissioner,             
          88 T.C. 654, 662 (1987).  However, in limited situations, the               
          section 6653(a) additions to tax may be avoided if the taxpayer             
          shows good faith reliance on the advice of a competent and                  
          experienced accountant or attorney in the preparation of the tax            
          return.  Weis v. Commissioner, 94 T.C. 473, 487 (1990); Conlorez            
          Corp. v. Commissioner, 51 T.C. 467, 474 (1968).  In order to show           
          good faith reliance, the taxpayer must establish that all                   
          necessary information was supplied to the return preparer and               
          that the incorrect return resulted from the preparer’s mistakes.            
          Weis v. Commissioner, supra at 487; Pessin v. Commissioner, 59              
          T.C. 473, 489 (1972).                                                       
               The evidence in the record indicates that Mr. Norris is a              
          competent and experienced accountant.  The parties agree that Mr.           






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