Robert Cotton, Jr. - Page 15




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          or regulations.  See sec. 6662(a) and (b)(1).  “Negligence”                 
          consists of any failure to make a reasonable attempt to comply              
          with the provisions of the Internal Revenue Code.  See sec.                 
          6662(c).  “Disregard” consists of any careless, reckless, or                
          intentional disregard.  Id.                                                 
               An exception applies to the accuracy-related penalty when              
          the taxpayer demonstrates (1) there was reasonable cause for the            
          underpayment, and (2) the taxpayer acted in good faith with                 
          respect to such underpayment.  See sec. 6664(c).  Whether the               
          taxpayer acted with reasonable cause and in good faith is                   
          determined by the relevant facts and circumstances.  The most               
          important factor is the extent of the taxpayer’s effort to assess           
          the proper tax liability.  See Stubblefield v. Commissioner, T.C.           
          Memo. 1996-537; sec. 1.6664-4(b)(1), Income Tax Regs.  Section              
          1.6664-(b)(1), Income Tax Regs., specifically provides:                     
          “Circumstances that may indicate reasonable cause and good faith            
          include an honest misunderstanding of fact or law that is                   
          reasonable in light of all of the facts and circumstances,                  
          including the experience, knowledge, and education of the                   
          taxpayer.”  See Neely v. Commissioner, 85 T.C. 934 (1985).                  
               A taxpayer is generally charged with knowledge of the law.             
          See Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).                  
          Ignorance of the law is not always a defense to the imposition of           








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