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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 addition to tax 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. 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);
sec. 1.6664-4(b)(1), Income Tax Regs. 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
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