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includes any careless, reckless, or intentional disregard of the
Code and the temporary or final regulations issued under the
Code. Sec. 6662(c); sec. 1.6662-3(b)(2), Income Tax Regs.
The accuracy-related penalty under 6662(a) does not apply to
any portion of an underpayment if it is shown that there was a
reasonable cause for such portion and that the taxpayer acted in
good faith with respect to such portion. Sec. 6664(c)(1). The
determination of whether the taxpayer acted with reasonable cause
and in good faith depends upon the pertinent facts and circum-
stances. Sec. 1.6664-4(b)(1), Income Tax Regs. Factors taken
into account include the taxpayer's efforts to assess his or her
proper tax liability and the knowledge and experience of the
taxpayer. Id. Reliance on the advice of a professional, such as
an accountant or an appraiser, does not necessarily demonstrate
reasonable cause and good faith unless, under all the circumstan-
ces, such reliance was reasonable and the taxpayer acted in good
faith. Id.
Although petitioner's argument is not entirely clear, he
appears to contend that he was not negligent in the preparation
of his 1991 return because the claimed charitable contribution
deduction was based on the advice of his accountant who prepared
that return and on the advice of Mr. Hetz who, he claims, pre-
pared the report attached to his 1991 return that indicated that
the fair market value of the Mark IV helmet that was the subject
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