Marcel Toto Ngosso - Page 13

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          that if any portion of any underpayment required to be shown on a           
          return is due to negligence or disregard of the rules or                    
          regulations, then a taxpayer will be liable for a penalty equal             
          to 20 percent of the underpayment of tax required to be shown on            
          the return that is attributable to the taxpayer’s negligence or             
          disregard of the rules or regulations.  Sec. 6662(a) and (b)(1).            
          “Negligence” includes any failure to make a reasonable attempt to           
          comply with the provisions of the Code.  Sec. 6662(c).                      
          “Disregard” includes any careless, reckless, or intentional                 
          disregard.  Id.                                                             
               The penalties provided for in section 6662 will not be                 
          imposed with respect to any portion of an underpayment if it is             
          shown that there was reasonable cause for such portion and that             
          the taxpayer acted in good faith with respect to such portion.              
          Sec. 6664(c)(1).  Whether the taxpayer has acted with reasonable            
          cause and in good faith is determined by relevant facts and                 
          circumstances, including the taxpayer’s own efforts to assess his           
          proper tax liability.  Stubblefield v. Commissioner, T.C. Memo.             
          1996-537; sec. 1.6664-4(b), Income Tax Regs.                                
               Respondent determined in the notice of deficiency that                 
          petitioner is liable for an accuracy-related penalty of $784                
          under section 6662(a) for 1996 because of negligence or disregard           
          of rules or regulations.                                                    

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