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and in good faith depends on the pertinent facts and circum-
stances, including the taxpayer's efforts to assess such tax-
payer’s proper tax liability, the knowledge and experience of the
taxpayer, and the reliance on the advice of a professional, such
as an accountant. Sec. 1.6664-4(b)(1), Income Tax Regs. Reli-
ance 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 this connection, a
taxpayer must demonstrate that its reliance on the advice of a
professional concerning substantive tax law was objectively
reasonable. Chamberlain v. Commissioner, 66 F.3d 729, 732-733
(5th Cir. 1995), affg. in part and revg. in part T.C. Memo. 1994-
228; Goldman v. Commissioner, 39 F.3d 402, 408 (2d Cir. 1994),
affg. T.C. Memo. 1993-480. 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 accountant's error.
Westbrook v. Commissioner, 68 F.3d 868, 881 (5th Cir. 1995),
affg. T.C. Memo. 1993-634; Weis v. Commissioner, 94 T.C. 473, 487
(1990); Ma-Tran Corp. v. Commissioner, 70 T.C. 158, 173 (1978).
In the instant case, respondent determined that there was an
understatement of $5,004,095 in petitioner’s 1993 return that was
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