- 23 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011