Frank W. George - Page 22




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          D.   Whether Petitioner Is Liable for Accuracy-Related                       
               Penalties for 1993 and 1994                                             
               Respondent determined that petitioner is liable for                     
          accuracy-related penalties for negligence under section 6662(a)              
          for 1993 and 1994.                                                           
               Taxpayers are liable for a penalty under section 6662 equal             
          to 20 percent of the part of the underpayment which is                       
          attributable to negligence.  See sec. 6662(a).  For purposes of              
          section 6662(a), negligence is a failure to make a reasonable                
          attempt to comply with the Internal Revenue Code.  See sec.                  
          6662(c).  The accuracy-related penalty under section 6662(a) does            
          not apply to any part of an underpayment if the taxpayer shows               
          that there was reasonable cause for that part of the underpayment            
          and that the taxpayer acted in good faith based on the facts and             
          circumstances.  See sec. 6664(c)(1).  A taxpayer may establish               
          that he or she had reasonable cause and was not negligent under              
          section 6662(a) by proving that he or she reasonably relied in               
          good faith on the advice of a competent, independent expert or               
          tax professional possessed of all the information.  See United               
          States v. Boyle, 469 U.S. 241, 250 (1985); Leonhart v.                       
          Commissioner, 414 F.2d 749, 750 (4th Cir. 1969), affg. T.C. Memo.            
          1968-98; Ewing v. Commissioner, 91 T.C. 396, 423 (1988), affd.               
          without published opinion 940 F.2d 1534 (9th Cir. 1991).                     
               Petitioner contends that he is not liable under section                 
          6662(a) because he relied on Chisum.  We disagree.  Chisum claims            





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