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liability. Stubblefield v. Commissioner, supra; sec. 1.6664-
4(b)(1), Income Tax Regs.
Petitioner took the position that she should be relieved of
the section 6662(a) penalties due to reliance on her income tax
return preparer. In general, taxpayers are dutybound to file
complete and accurate tax returns. United States v. Boyle, 469
U.S. 241, 250-251 (1985). They may not avoid this duty simply by
relying on a return preparer. Id. Thus, blind reliance on a
return preparer is not a defense to negligence, and taxpayers are
required to review their return before signing it. Metra Chem
Corp. v. Commissioner, 88 T.C. 654, 662 (1987).
Petitioner did not convince the Court that she acted with
reasonable cause and in good faith. She presented no evidence of
having taken reasonable steps to determine the law and to comply
with it regarding the various issues of her case. Her lack of
substantiation on these issues supports the imposition of a
penalty, and the bare argument of having relied on a return
preparer is unpersuasive. Petitioner is therefore liable for the
section 6662(a) penalties for the years in question. Respondent
is sustained on this issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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