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or regulations. See sec. 6662(a) and (b)(1). “Negligence”
consists of any failure to make a reasonable attempt to comply
with the provisions of the Internal Revenue Code. See sec.
6662(c). “Disregard” consists of any careless, reckless, or
intentional disregard. Id.
An exception applies to the accuracy-related penalty when
the taxpayer demonstrates (1) there was reasonable cause for the
underpayment, and (2) the taxpayer acted in good faith with
respect to such underpayment. See sec. 6664(c). Whether the
taxpayer acted with reasonable cause and in good faith is
determined by the relevant facts and circumstances. The most
important factor is the extent of the taxpayer’s effort to assess
the proper tax liability. See Stubblefield v. Commissioner, T.C.
Memo. 1996-537; sec. 1.6664-4(b)(1), Income Tax Regs. Section
1.6664-(b)(1), Income Tax Regs., specifically provides:
“Circumstances that may indicate reasonable cause and good faith
include an honest misunderstanding of fact or law that is
reasonable in light of all of the facts and circumstances,
including the experience, knowledge, and education of the
taxpayer.” See Neely v. Commissioner, 85 T.C. 934 (1985).
A taxpayer is generally charged with knowledge of the law.
See Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).
Ignorance of the law is not always a defense to the imposition of
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