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Pritchett v. Commissioner, 63 T.C. 149, 174 (1974). A taxpayer
bears the responsibility for any negligent errors of his or her
accountant. American Properties, Inc. v. Commissioner, 28 T.C.
1100, 1116-1117 (1957), affd. per curiam 262 F.2d 150 (9th Cir.
1958). However, a taxpayer may avoid the accuracy-related penalty
under section 6662(a) for negligence or substantial understate-
ment by showing that his reliance on the advice of a profes-
sional, such as an accountant, was reasonable and in good faith.
Sec. 1.6664-4(b)(1), Income Tax Regs. In the case of claimed
reliance on the accountant who prepared the taxpayer's return,
the taxpayer must establish that correct information was provided
to the accountant and that the item incorrectly claimed or
reported in the return was the result of the accountant's error.
See Ma-Tran Corp. v. Commissioner, 70 T.C. 158, 173 (1978). A
taxpayer's reliance on the advice of an accountant is not reason-
able or in good faith where a cursory review of a taxpayer's
return would reveal an omission from income. Metra Chem Corp. v.
Commissioner, 88 T.C. 654, 662 (1987).
We note initially that with respect to the items that
respondent contends were due to negligence, disregard of the
rules or regulations, or a substantial understatement of income
tax, the record contains evidence only as to the items specifi-
cally identified and discussed below. The record does not
contain any evidence as to the remainder of those items (remain-
ing items) on all of which petitioner bears the burden of proof;
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