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sec. 1.6664-4(b)(1), Income Tax Regs. Under section 1.6664-
4(b)(1), Income Tax Regs., "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." Moreover, a taxpayer
is generally charged with knowledge of the law. Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992). Although a taxpayer is
not subject to the penalty for negligence where the taxpayer
makes honest mistakes in complex matters, the taxpayer must take
reasonable steps to determine the law and to comply with it. Id.
Under certain circumstances, a taxpayer may avoid the
accuracy-related penalty for negligence where the taxpayer
reasonably relied on the advice of a competent professional.
Sec. 1.6664-4(b)(1), Income Tax Regs.; see also sec. 6664(c);
Freytag v. Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d
1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991). Reliance on a
professional adviser, standing alone, is not an absolute defense
to negligence; it is only one factor to be considered. In order
for reliance on a professional adviser to relieve a taxpayer from
the negligence penalty, the taxpayer must establish that the
professional adviser on whom he or she relied had the expertise
and knowledge of the relevant facts to provide informed advice on
the subject matter. Freytag v. Commissioner, supra at 888.
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