10.22—Diligence as to accuracy.
        
        (1) 
         In preparing or assisting in the
 preparation of, approving, and filing tax returns,
 documents, affidavits, and other papers relating
 to Internal Revenue Service matters;
    
    
        
        (2) 
         In determining the correctness of oral or
 written representations made by the practitioner
 to the Department of the Treasury; and
    
    
        
        (3) 
         In determining the correctness of oral or
 written representations made by the practitioner
 to clients with reference to any matter
 administered by the Internal Revenue Service.
    
    
        
        (b) Reliance on others.
         Except as
 provided in  §§ 10.34, 10.35, and 10.37, a
 practitioner will be presumed to have exercised
 due diligence for purposes of this section if the
 practitioner relies on the work product of another
 person and the practitioner used reasonable care
 in engaging, supervising, training, and evaluating
 the person, taking proper account of the nature of
 the relationship between the practitioner and the
 person.