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Section 6662(c) provides that “<negligence’ includes any
failure to make a reasonable attempt to comply with the * * *
[Code]". Section 6662(c) also provides that “<disregard’
includes any careless, reckless, or intentional disregard.”
Negligence includes a “lack of due care or failure to do what a
reasonable and ordinarily prudent person would do in a similar
situation”. Niedringhaus v. Commissioner, 99 T.C. 202, 221
(1992) (citing Neely v. Commissioner, 85 T.C. 934, 947 (1985)).
Although a taxpayer remains liable for a deficiency
attributable to a return prepared by an accountant, a taxpayer
who supplies a qualified tax return preparer with all relevant
information and who reasonably and in good faith relies on the
preparer’s advice is not negligent and has not disregarded rules
and regulations, even if the advice is incorrect and results in a
deficiency. Heasley v. Commissioner, 902 F.2d 380 (5th Cir.
1990), revg. T.C. Memo. 1988-408; Betson v. Commissioner, 802
F.2d 365 (9th Cir. 1986), affg. in part and reversing in part
T.C. Memo. 1984-264; Industrial Valley Bank & Trust Co. v.
Commissioner, 66 T.C. 272 (1976); Hill v. Commissioner, 63 T.C.
225 (1974), affd. without published opinion sub nom. Tenner v.
Commissioner, 551 F.2d 313 (9th Cir. 1977); Conlorez Corp. v.
Commissioner, 51 T.C. 467 (1968); Brown v. Commissioner, 47 T.C.
399 (1967), affd. per curiam 398 F.2d 832 (6th Cir. 1968). The
taxpayer has the burden of proving that he supplied the correct
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