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proper tax liability, the knowledge and experience of the tax-
payer, and the reliance on the advice of a professional, such as
an accountant. Sec. 1.6664-4(b)(1), Income Tax Regs. Reliance
on the advice of a professional, such as an accountant, does not
necessarily demonstrate reasonable cause and good faith unless,
under all the circumstances, such reliance was reasonable and the
taxpayer acted in good faith. Id. In the case of claimed
reliance on the accountant who prepared the taxpayer’s tax
return, the taxpayer must establish that correct information was
provided to the accountant and that the item incorrectly omitted,
claimed, or reported in the return was the result of the accoun-
tant’s error. Ma-Tran Corp. v. Commissioner, 70 T.C. 158, 173
(1978).
On the record before us, we find that respondent has satis-
fied the burden of production that respondent maintains respon-
dent has with respect to the respective accuracy-related penal-
ties under section 6662(a) that respondent determined to impose
on Ms. Herbst and on Mr. Herbst for the taxable years 1996 and
1997.13
Based on our examination of the entire record before us, we
shall grant respondent’s motion in the case at docket No. 10001-
13We are not deciding in the cases at docket Nos. 10001-00
and 10002-00 whether the Commissioner of Internal Revenue has the
burden of production in cases subject to sec. 7491(c) when a
taxpayer fails to appear for trial.
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