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"disregard" includes any careless, reckless, or intentional
disregard. Sec. 6653(a)(3).
Negligence is defined as a lack of due care or the failure
to do what a reasonable and ordinarily prudent person would do
under the circumstances. Zmuda v. Commissioner, 731 F.2d 1417,
1422 (9th Cir. 1984), affg. 79 T.C. 714 (1982); Neely v.
Commissioner, 85 T.C. 934, 947 (1985). However, reasonable
reliance upon expert opinion, asserted in good faith, can shield
a taxpayer from section 6653(a) additions to tax. United States
v. Boyle, 469 U.S. 241, 250 (1985); Collins v. Commissioner, 857
F.2d 1383, 1386 (9th Cir. 1988), affg. T.C. Memo. 1987-217.
We find that Jacobs reasonably relied upon the expert
opinions of Ingram and Ewing, as well as those contained in the
Adamson report, when he claimed the charitable deduction at
issue. Both Ingram and Ewing were licensed real estate
appraisers in California. Their valuation report is detailed and
complete, and was attached to Jacobs' Federal income tax return
for taxable year 1986. While Jacobs has considerable knowledge
regarding real estate development, we think the evidence of his
knowledge falls short of requiring him to second-guess licensed
appraisers. Hence, under these circumstances, we do not find
Jacobs negligent. Accordingly, we hold that he is not liable for
the section 6653(a) addition to tax for negligence for 1988.
B. Accuracy-Related Penalties
For 1989 and 1990, section 6662(a) imposes an accuracy-
related penalty of an amount equal to 20 percent of the portion
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