Definitely 3, though if you remove some of those results with Tough Luck, it seems like they shouldn't count.
Let's look at Accuracy from the rules reference:
"The attacker’s total Accuracy is determined by adding all numbers rolled on dice, and applying any Accuracy modifiers provided by abilities"
Are you saying that if you remove the results on a die with a number on it, the number still counts for accuracy? According to the logic above, it says add up numbers on rolled dice. So it is impossible to reduce a player's accuracy with Tough Luck?
This seems a little ridiculous.
Edited by DTDanix