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Commissioner, 85 T.C. 731, 743 (1985). Petitioner has not shown
that he is entitled to a basis in any of the automobiles in issue
in excess of that determined by respondent.
Respondent also determined that petitioner is liable for an
addition to tax for negligence or intentional disregard of rules
or regulations. Section 6653(a)(1)(A) imposes an addition to tax
equal to 5 percent of the entire underpayment if any part of the
underpayment is due to negligence. Section 6653(a)(1)(B) imposes
an addition to tax equal to 50 percent of the interest payable
under section 6601 with respect to the portion of the
underpayment that is due to negligence. This Court has defined
negligence as a lack of due care or failure to do what a
reasonable and ordinarily prudent person would do under the
circumstances. McGee v. Commissioner, 979 F.2d 66, 71 (5th Cir.
1992), affg. T.C. Memo. 1991-510; Neely v. Commissioner, 85 T.C.
934, 947 (1985).
We have declined to sustain additions to tax for negligence
where taxpayers have relied reasonably and in good faith on the
advice of tax experts. Metra Chem Corp. v. Commissioner, 88 T.C.
654, 662 (1987); Weis v. Commissioner, 94 T.C. 473, 487 (1990).
To demonstrate such good faith reliance, taxpayers must establish
that they supplied their return preparer with all necessary
information, and the incorrect return was a result of the
preparer's mistakes. Weis v. Commissioner, supra at 487; Pessin
v. Commissioner, 59 T.C. 473, 489 (1972). Respondent's
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