Florence C. Blankson - Page 24




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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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