Taxpayer “negligence” under Subsection 7-1-69A NMSA 1978 means:

1. A. failure to exercise that degree of ordinary business care and prudence which reasonable taxpayers would exercise under like circumstances;
2. B. inaction by taxpayers where action is required;

3. C. inadvertance, indifference, thoughtlessness, carelessness, erroneous belief or inattention.

   [11/5/85, 8/15/90, 10/31/96; 3.1.11.10 NMAC - Rn & A, 3 NMAC 1.11.10, 1/15/01]