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resolve the issue presented under section 6662(a).8 See Rule
143(b).
We address now petitioners’ position that they “used reason-
able care in the preparation of their tax returns” and “should
not be penalized as allowed by Sec. 6664(c)(1).” Pursuant to
section 6664(c)(1), the accuracy-related penalty under section
6662(a) does not apply to any portion of an underpayment if it is
shown that there was reasonable cause for, and that the taxpayer
acted in good faith with respect to, such portion. The determi-
nation of whether the taxpayer acted with reasonable cause and in
good faith depends on the pertinent facts and circumstances.
Sec. 1.6664-4(b)(1), Income Tax Regs. “Generally, the most
important factor is the extent of the taxpayer’s effort to assess
the taxpayer’s proper tax liability. Circumstances that may
indicate reasonable cause and good faith include * * * the
experience, knowledge, and education of the taxpayer.” Id.
Although reliance on an information return does not necessarily
demonstrate reasonable cause and good faith, such reliance
“constitutes reasonable cause and good faith if, under all the
circumstances, such reliance was reasonable and the taxpayer
acted in good faith.” Id.
8Petitioners advance on brief certain factual allegations in
addition to those quoted above, which we also find are not
supported by the instant record and on which we shall not rely.
See Rule 143(b). In addition, petitioners attached certain
documents to their brief. To the extent those attached documents
are not a part of the record in this case, the Court has disre-
garded them. See Rule 143(b).
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