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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 proper tax liability. See id. An honest misunderstanding of
fact or law that is reasonable in light of the experience,
knowledge, and education of the taxpayer may indicate reasonable
cause and good faith. Remy v. Commissioner, T.C. Memo. 1997-72.
Further, reliance by the taxpayer on the advice of a qualified
adviser constitutes reasonable cause and good faith, if, under
all of the facts and circumstances, the reliance by the taxpayer
was reasonable and the taxpayer acted in good faith. Sec.
1.6664-4(b)(1), Income Tax Regs.
In his petition, petitioner alleges that his health-related
problems rendered him incapable of verifying the accuracy of his
2002 income tax return. He contends that an infection in both
eyes left him unable to see or read in April 2003, the time when
the return for taxable year 2002 was filed. At trial, petitioner
testified that he acquired a serious bacterial infection in his
left eye sometime in October 2001. He acknowledged that his eyes
were examined by a professional, and that the infection’s effects
were limited to his left eye. Notwithstanding the infection in
his left eye, petitioner was able to finish his coursework at
Loyola University New Orleans College of Law, take his exams, and
graduate from law school in 2003. Because the infection, which
originated in October 2001, only impaired one eye, the Court is
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