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care or failure to do what a reasonable and ordinarily prudent
person would do under the circumstances. See Neely v.
Commissioner, 85 T.C. 934, 947 (1985). It is well established
that the taxpayer bears the burden of proof on this issue. See
Bixby v. Commissioner, 58 T.C. 757, 791 (1972).
The determination of whether a taxpayer acted with
reasonable cause and in good faith depends upon the facts and
circumstances of each particular case. See sec. 1.6664-4(b)(1),
Income Tax Regs. Relevant factors include the taxpayer's efforts
to assess his or her proper tax liability, the knowledge and
experience of the taxpayer, and reliance on the advice of a
professional, such as an accountant. See Drummond v.
Commissioner, T.C. Memo. 1997-71. However, the most important
factor is the extent of the taxpayer's effort to determine the
taxpayer's proper tax liability. See sec. 1.6664-4(b)(1), Income
Tax Regs. An honest misunderstanding of fact or law that is
reasonable in light of the experience, knowledge, and education
of the taxpayer may indicate reasonable cause and good faith.
See Remy v. Commissioner, T.C. Memo. 1997-72.
Petitioner did not directly address this issue at trial;
consequently, the Court decides the issue on the totality of the
evidence presented. In that light, the Court notes that
petitioner conceded the disallowed utility expenses he had
claimed on his 1994 and 1995 returns. Petitioner did not
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