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         Generally, the most important factor is the extent of the                    
         taxpayer’s efforts to evaluate his proper tax liability.  Id.                
         Reliance on the advice of a professional tax adviser does not                
         necessarily demonstrate reasonable cause and good faith.  Id.                
              The responsibility to file returns and pay tax when due                 
         rests upon the taxpayer and cannot be delegated, and the                     
         taxpayer, generally, must bear the consequences of any negligent             
         errors committed by his or her agent.  Pritchett v. Commissioner,            
         63 T.C. 149, 173-175 (1974); Ellwest Stereo Theatres, Inc. v.                
         Commissioner, T.C. Memo. 1995-610.                                           
              For a taxpayer to rely reasonably upon advice so as to                  
         negate a section 6662(a) accuracy-related penalty determined by              
         the Commissioner, the taxpayer must prove by a preponderance of              
         the evidence that the taxpayer meets all of the following                    
         requirements:  (1) The adviser was a competent professional who              
         had sufficient expertise to justify reliance, (2) the taxpayer               
         provided necessary and accurate information to the adviser, and              
         (3) the taxpayer actually relied in good faith on the adviser’s              
         judgment.  See Neonatology Associates, P.A. v. Commissioner, 115             
         T.C. 43, 99 (2000), affd. 299 F.3d 221 (3d Cir. 2002); Ellwest               
         Stereo Theatres v. Commissioner, supra.                                      
              Petitioner testified that, in the preparation of her tax                
         return, she submitted “everything” to her C.P.A.  Once the return            
         had been prepared, petitioner signed it without reviewing the                






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