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Petitioners attempt to shift the responsibility for the
understatements of their tax liabilities to Greenfield and claim
that Greenfield should have conducted his own investigation into
the accuracy of the information that petitioners provided to him
in the course of his preparation of their returns. However, in
the course of his preparation of petitioners’ tax returns,
Greenfield was not provided with documentation to support
petitioners’ calculations of the figures given to him other than
some contracts for the purchase of equipment. Petitioners’
reliance on Greenfield to discover the errors in the reported
figures is no defense to fraud because they failed to provide
Greenfield with complete and accurate information regarding their
income and expenses. See Korecky v. Commissioner, 781 F.2d 1566,
1569 (11th Cir. 1986), affg. per curiam T.C. Memo. 1985-63;
Merritt v. Commissioner, 301 F.2d 484, 487 (5th Cir. 1962), affg.
T.C. Memo. 1959-172.
Although Greenfield testified that “it was obvious that the
[1998] tax return wasn’t correct”, he was able to reach this
conclusion only after petitioners provided him with their books
and records after the returns had been filed. The responsibility
of filing accurate returns remains principally with the
taxpayers, especially where the taxpayers have taken an active
and controlling role in the process of preparing the tax returns
and the information used for their preparation. See Medlin v.
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