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taxpayer demonstrates (1) there was reasonable cause for the
underpayment, and (2) the taxpayer acted in good faith with
respect to the 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 the proper tax
liability. Stubblefield v. Commissioner, T.C. Memo. 1996-537;
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. 1.6664-4(b)(1), Income Tax Regs.; sec. 6664(c); Freytag v.
Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d 1011 (5th
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