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"Disregard" includes any careless, reckless, or intentional
disregard of rules or regulations. Sec. 6662(c); sec.
1.6662-3(b)(2), Income Tax Regs.
Section 6664(c)(1), however, provides that the penalty under
section 6662(a) shall not apply to any portion of an
underpayment, if it is shown that there was reasonable cause for
the taxpayer's position with respect to that portion and that the
taxpayer acted in good faith with respect to that portion. The
determination of whether a taxpayer acted with reasonable cause
and in good faith is made on a case-by-case basis, taking into
account all the pertinent facts and circumstances. Sec.
1.6664-4(b)(1), Income Tax Regs. The most important factor is
the extent of the taxpayer's effort to assess his proper tax
liability for the year. Id.
The following dialogue at trial concerning petitioner's
failure to substantiate his medical expenses for 1992 illustrates
his lack of effort to assess his proper tax liability:
Q Did you, in fact, contact any doctor or hospital to
get such records?
A I went to contact somebody, and they told me that I
needed to come in and go through the process of going
and doing the microfilms or whatever. And I just --
didn't go. No.
Based on the record, we find that petitioner has not proved
that his underpayment was due to reasonable cause or that he
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