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returns and that petitioner's accountant was not qualified to
render tax advice. Petitioner bears the burden of proving that
respondent's determination is erroneous. Rule 142(a); INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Bixby v.
Commissioner, 58 T.C. 757, 791 (1972).
Section 6662(a) imposes an accuracy related penalty of
20 percent on any portion of an underpayment of tax that is
attributable to items set forth in section 6662(b). Section
6662(b)(2) specifies as one of those items "Any substantial
understatement of income tax." An understatement is substantial
if it exceeds the greater of 10 percent of the tax required to be
shown on the return or $10,000. Sec. 6662(d)(1)(A) and (B). In
calculating understatements under section 6662(b)(2), items for
which there was substantial authority are not to be considered.
Sec. 6662(d)(2)(B)(i). To determine whether the treatment of any
portion of an understatement is supported by substantial
authority, the weight of authorities in support of the taxpayer's
position must be substantial in relation to the weight of
authorities supporting contrary positions. Antonides v.
Commissioner, 91 T.C. 686, 700-704 (1988), affd. 893 F.2d 656
(4th Cir. 1990); sec. 1.6662-4(d)(3), Income Tax Regs.
Petitioner argues that the weight of authorities supports
its position that the equipment was acquired by lease and not
acquired in a disguised sale. Petitioner relies on Revenue
Ruling 55-540, 1955-2 C.B. 39, and Benton v. Commissioner, 197
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