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rules and regulations. Section 6653(a)(2) provides for an
addition to tax equal to 50 percent of the interest payable under
section 6601 on that portion of the underpayment in tax
attributable to such negligence or intentional disregard.
Negligence is defined as the failure to exercise the due
care that a reasonable and ordinarily prudent person would employ
under the circumstances. Zmuda v. Commissioner, 731 F.2d 1417,
1422 (9th Cir. 1984), affg. 79 T.C. 714 (1982); Niedringhaus v.
Commissioner, 99 T.C. 202, 221 (1992); Neely v. Commissioner, 85
T.C. 934, 947 (1985). The question is whether a particular
taxpayer's actions in connection with the transactions were
reasonable in light of his experience and the nature of the
investment or business. See Henry Schwartz Corp. v.
Commissioner, 60 T.C. 728, 740 (1973). We also consider the
taxpayer's experience and knowledge in determining whether he
acted negligently or intentionally disregarded rules and
regulations. Vandeyacht v. Commissioner, T.C. Memo. 1994-148;
DeRochemont v. Commissioner, T.C. Memo. 1991-600.
A taxpayer may avoid liability for the additions to tax
under section 6653(a)(1) and (2) by relying on competent
professional advice if it was reasonable to rely on such advice.
United States v. Boyle, 469 U.S. 241, 250-251 (1985); Freytag v.
Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d 1011, 1017
(5th Cir. 1990), affd. 501 U.S. 868 (1991). Reliance on
professional advice, standing alone, is not an absolute defense
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