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Petitioner has not addressed these issues and is deemed to
have conceded them. Therefore, we sustain respondent on these
issues.
VIII. Accuracy-Related Penalty Under Section 6662(a)
Respondent determined that petitioner is liable for the
accuracy-related penalty under section 6662(a). As pertinent
here, section 6662(a) imposes a 20-percent penalty on the portion
of an underpayment attributable to negligence or disregard of
rules or regulations. Sec. 6662(b)(1). Negligence includes any
failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue Code, including any failure to
keep adequate books and records or to substantiate items
properly. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
The penalty under section 6662(a) does not apply to any
portion of an underpayment of tax if it is shown that there was
reasonable cause for the taxpayer’s position and that the
taxpayer acted in good faith with respect to that portion. Sec.
6664(c)(1). The determination of whether a taxpayer acted with
reasonable cause and in good faith is made on a case-by-case
basis, taking into account all the pertinent facts and
circumstances. Sec. 1.6664-4(b)(1), Income Tax Regs. The most
important factor is the extent of the taxpayer’s effort to assess
his/her proper tax liability for the year. Id. The good faith
reliance on the advice of an independent, competent professional
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