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alimony within the meaning of section 71. Consequently, they are
not deductible to petitioner pursuant to section 215(a).
C. Section 6662(a) Penalty
Under section 6662, a penalty is imposed on that portion of
an underpayment of the tax required to be shown on a return if
the underpayment is due to negligence or disregard of rules or
regulations. Sec. 6662(a) and (b)(1). Negligence is defined to
include any failure to make a reasonable attempt to comply with
the provisions of the Internal Revenue Code. Sec. 6662(c). It
is further defined as the failure to do what a reasonable person
with ordinary prudence would do under the same or similar
circumstances. Neely v. Commissioner, 85 T.C. 934, 947 (1985).
Disregard is defined to include any careless, reckless, or
intentional disregard. Sec. 6662(c). An accuracy-related
penalty will not be imposed with respect to any portion of an
underpayment as to which the taxpayer acted with reasonable cause
and in good faith. Sec. 6664(c)(1). 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.
Circumstances that may indicate reasonable cause and good faith
include the extent of the taxpayer’s effort to properly assess
the tax liability and an honest misunderstanding of fact or law
that is reasonable in light of the taxpayer’s experience,
knowledge, and education. Id. The taxpayer bears the burden of
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