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part 43 T.C. 168 (1964); Neely v. Commissioner, 85 T.C. 934, 947
(1985).
There is a substantial understatement of income tax if the
amount of the understatement for the taxable year exceeds the
greater of 10 percent of the amount required to be shown on the tax
return, or $5,000. Sec. 6662(d)(1)(A). The amount of the
understatement is reduced, however, if there was substantial
authority for the taxpayer's treatment of the item. Sec.
6662(d)(2)(B). In order to satisfy the substantial authority
standard, petitioner must show that the weight of authorities
supporting her position is substantial in relation to those
supporting a contrary position. Antonides v. Commissioner, 91 T.C.
686, 702 (1988), affd. 893 F.2d 656 (4th Cir. 1990); sec. 1.6661-
3(b)(1), Income Tax Regs.
Petitioner has the burden of proving that respondent's
determination of the accuracy-related penalty is in error. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Petitioner
conceded that she is liable for the accuracy-related penalty with
respect to those items that she conceded at or before trial and on
brief. With respect to those items still in issue, petitioner
simply claims that her positions were supported by substantial
authorities. However, petitioner provided no evidence to show that
she was not negligent, and she pointed to no authorities to support
her position and bring her within the exception to the definition
of substantial understatement. Accordingly, we sustain
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