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An exception applies to the accuracy-related penalty when
the taxpayer demonstrates (1) there was reasonable cause for the
underpayment, and (2) he acted in good faith with respect to such
underpayment. 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.
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). Rule 142(a); Tweeddale v. Commissioner, 92 T.C. 501,
505 (1989). Petitioner did not address this issue at trial.
Petitioner claimed deductions that he failed to explain or
substantiate. Petitioner is an accountant who presumably should
be familiar with the provisions of the Internal Revenue Code
applicable to his case; yet he did not follow the applicable law
in preparing his Federal income tax returns. On the basis of the
entire record, we conclude petitioner has not established that
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