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The remaining issue is whether petitioner is liable for the
accuracy-related penalty under section 6662(a) for negligence
under section 6662(c). Generally, this penalty is applicable to
any underpayment of tax attributable to negligence or disregard
of rules or regulations. Section 6662(c) provides that the term
"negligence" includes any failure to make a reasonable attempt to
comply with the provisions of this title, and the term
"disregard" includes any careless, reckless, or intentional
disregard. Negligence has also been defined as lack of due care
or failure to do what a reasonable and ordinarily prudent person
would do under like circumstances. Neely v. Commissioner, 85
T.C. 934 (1985). However, under section 6664(c), the penalty
under section 6662(a) shall not be imposed with respect to any
portion of an underpayment if it is shown that there was
reasonable cause for the underpayment, and the taxpayer acted in
good faith. Petitioner is sustained on this issue. The Court is
satisfied that petitioner acted in good faith in claiming the
disputed travel expenses for 1991. There were no regulations
that had been promulgated to reflect the intent of Congress in
the enactment of section 274(m)(2) and to particularize those
travel expenses relating to education that were not affected by
section 274(m)(2). For the year in question, therefore, there
was no clear-cut guide by which taxpayers, such as petitioner,
could have ascertained whether the travel expenses incurred were
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