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and (b)(1). Negligence is any failure to make a reasonable
attempt to comply with the provisions of the Internal Revenue
laws. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
Moreover, negligence is the failure to exercise due care or the
failure to do what a reasonable and prudent person would do under
the circumstances. Neely v. Commissioner, 85 T.C. 934, 947
(1985). Disregard includes any careless, reckless, or
intentional disregard of rules or regulations. Sec. 6662(c);
sec. 1.6662-3(b)(2), Income Tax Regs.
No penalty will be imposed with respect to any portion of
any underpayment if it is shown that there was a reasonable cause
for such portion and that the taxpayer acted in good faith with
respect to such portion. Sec. 6664(c). Where the taxpayer
claims reliance on an accountant who prepared the taxpayer's
return, the taxpayer must establish that the correct information
was provided to the accountant and that the item incorrectly
claimed or reported in the return was the result of the
accountant's error. Ma-Tran Corp. v. Commissioner, 70 T.C. 158,
173 (1978); Enoch v. Commissioner, 57 T.C. 781, 803 (1972).
Petitioner did not keep any records of his purported music
business and he did not have a separate bank account. He did not
carry on this activity in businesslike fashion, as we detailed
above. Other than asserting that he relied on the advice of his
accountant, petitioner presented no testimony or other evidence
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