- -20
Based on the evidence in this record, we sustain
respondent's disallowance of petitioner's claimed deduction for
the cost of truck tires purchased in its fiscal year 1990.
Next at issue is whether petitioner is liable for an
accuracy-related penalty pursuant to section 6662(b)(2).
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 for
the taxable year or for a corporation $10,000. Sec.
6662(d)(1)(B).
Section 6662(d)(2)(B) states that the amount of the
understatement shall be reduced by the portion of the
understatement which is attributable to the tax treatment of any
item if there is or was substantial authority for such treatment,
or if the relevant facts affecting the item's tax treatment are
adequately disclosed on the return or in a statement attached to
the return, and there is a reasonable basis for the tax treatment
of such item. 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
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