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Sec. 6664(c)(1). The decision as to whether the taxpayer acted
with reasonable cause and in good faith depends upon all
pertinent facts and circumstances. Sec. 1.6664-4(b)(1), Income
Tax Regs. Generally, the most important factor is the extent of
the taxpayer's efforts to assess the proper tax liability. Id.
A taxpayer must establish error in the determination that he or
she is liable for the penalty provided by section 6662(a). Rule
142(a); Estate of Monroe v. Commissioner, 104 T.C. 352, 366
(1995).
On brief, petitioner contends that she believed in good
faith that the expenses that she claimed were allowable. Good
faith on the part of a taxpayer, however, does not always negate
negligence. Taxpayers are required to take reasonable steps to
determine the law and to comply with it. Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992). In the instant case,
petitioner has not shown that her claimed deductions for expenses
were made with any significant regard to whether they were
personal in nature, and the record supports the inference that
petitioner's photography activity was used to deduct personal
expenses. We do not consider petitioner to have acted reasonably
with respect to the deduction of those expenses claimed for her
photography activity. Moreover, petitioner failed to investigate
the qualifications of any of the persons owning or operating
United Sovereigns or of Mr. Webber before enlisting them to
prepare her tax returns for the years in issue. Based on our
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