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underpayment, and (2) he 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 his proper tax liability. See
Stubblefield v. Commissioner, T.C. Memo. 1996-537; sec. 1.6664-
4(b)(1), Income Tax Regs. Section 1.6664-4(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
* * * the experience, knowledge, and education of the taxpayer.”
See Neely v. Commissioner, 85 T.C. 934 (1985).
It is the taxpayer’s responsibility to establish that he is
not liable for the accuracy-related penalty imposed by section
6662(a). See Rule 142(a); Tweeddale v. Commissioner, 92 T.C.
501, 505 (1989).
Petitioners appear to argue that they relied on their tax
preparer, Price Waterhouse. Under certain circumstances,
reliance by a taxpayer on the advice of a competent adviser can
be a defense to the accuracy-related penalty. See United States
v. Boyle, 469 U.S. 241, 250-251 (1985); Ewing v. Commissioner, 91
T.C. 396, 423–424 (1988), affd. without published opinion 940
F.2d 1534 (9th Cir. 1991). However, reliance on professional
advice, standing alone, is not an absolute defense to negligence
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