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We disagree with all of petitioners’ assertions as to the
accuracy-related penalties determined by respondent under section
6662(a) and (b)(1). Section 6662(a) and (b)(1) imposes a 20-
percent accuracy-related penalty on the portion of an
underpayment that is due to negligence or intentional disregard
of rules or regulations. Negligence includes a failure to
attempt reasonably to comply with the Code. See sec. 6662(c).
Disregard includes a careless, reckless, or intentional
disregard. See id. An underpayment is not attributable to
negligence or disregard to the extent that the taxpayer shows
that the underpayment is due to the taxpayer’s reasonable cause
and good faith. See secs. 1.6662-3(a), 1.6664-4(a), Income Tax
Regs.
Reasonable cause requires that the taxpayer have exercised
ordinary business care and prudence as to the disputed item. See
United States v. Boyle, 469 U.S. 241 (1985); see also Hatfried,
Inc. v. Commissioner, 162 F.2d 628, 635 (3d Cir. 1947); Girard
Inv. Co. v. Commissioner, 122 F.2d 843, 848 (3d Cir. 1941);
Estate of Young v. Commissioner, 110 T.C. 297, 317 (1998). The
good faith reliance on the advice of an independent, competent
professional as to the tax treatment of an item may meet this
requirement. See United States v. Boyle, supra; sec. 1.6664-
4(b), Income Tax Regs.; see also Hatfried, Inc. v. Commissioner,
supra at 635; Girard Inv. Co. v. Commissioner, supra at 848;
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