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holdings herein. See sec. 6665(b)(1).
Respondent also determined that, for each of the years in
issue, petitioners are liable for the section 6662(a) accuracy-
related penalty due to their negligence or intentional disregard
of rules or regulations. For this purpose, negligence includes
any failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue Code, and disregard includes
any careless, reckless, or intentional disregard of rules or
regulations. Sec. 6662(c); sec. 1.6662-3(b), Income Tax Regs.
The accuracy-related penalty does not apply to any portion of an
underpayment to the extent the taxpayer shows there was
reasonable cause for such portion and that the taxpayer acted in
good faith. Sec. 6664(c)(1); secs. 1.6662-3(a), 1.6664-4(a),
Income Tax Regs. The decision as to whether a taxpayer acted
with reasonable cause and in good faith depends on all the facts
and circumstances relevant to the case with the most important
factor being the taxpayer’s efforts to assess the proper tax
liability. Jorgenson v. Commissioner, T.C. Memo. 2000-38; sec.
1.6664-4(b)(1), Income Tax Regs.
Petitioners treated the entire Maple Row cattle undertaking
as one activity. Portions of the underpayments that may remain
for the years in issue may be attributable to petitioners’
failure to treat as a separate activity the holding of the land
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