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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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