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under all the circumstances, such reliance was reasonable and the
taxpayer acted in good faith. Sec. 1.6664-4(b)(1), Income Tax
Regs. In this connection, a taxpayer must demonstrate that the
taxpayer’s reliance on the advice of a professional concerning
substantive tax law was objectively reasonable. 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 and complete information was provided to the accoun-
tant and that the item incorrectly omitted, claimed, or reported
in the return was the result of the accountant’s error. See
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).
Respondent has the burden of production under section
7491(c) with respect to the accuracy-related penalty under
section 6662(a). To meet that burden, respondent must come
forward with sufficient evidence showing that it is appropriate
to impose the accuracy-related penalty. Higbee v. Commissioner,
116 T.C. 438, 446 (2001). Although respondent bears the burden
of production with respect to the accuracy-related penalty at
issue, respondent “need not introduce evidence regarding reason-
able cause, substantial authority, or similar provisions. * * *
the taxpayer bears the burden of proof with regard to those
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