Tax Lawyer's Blog

Section 4.10.63.5.3 of the Internal Revenue Manual  is titled Reliance on Representative and/or Return Preparer and provides in part that,

In considering the failure to file penalty, the United States Supreme Court has held that the fact that a taxpayer relies on an attorney to file a timely tax return does not relieve the taxpayer of the duty to meet the tax return deadlines (see R.W. Boyle, 85–1 USTC 13,602, 105 S. CT. 687). 

IRS self-help tool number 13 titled Penalty Appeal states,

Reliance on the advice of a tax advisor/professional is limited to issues generally considered technical or complicated. Your responsibility to file, pay or deposit taxes cannot be excused by reliance on the advice of a tax advisor.

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