Section 6662(a) and (b)(2) imposes an accuracy-related
penalty equal to 20 percent of any portion of an underpayment
that is attributable to a substantial understatement of income
tax. An underpayment is defined as the excess of the tax imposed
pursuant to the Code over the amount of tax shown on the return
plus amounts not shown but previously assessed, less rebates.
Sec. 6664(a). A substantial understatement is one that exceeds
the greater of 10 percent of the tax required to be shown on the
taxpayer's return for the taxable year or $5,000. Sec.
6662(d)(1)(A). An understatement is defined as the excess of the
amount of tax required to be shown on the return over the amount
of tax which is shown on the return, reduced by any rebate. Sec.
6662(d)(2)(A). The amount of an understatement is reduced by the
portion of the understatement attributable to the tax treatment
of any item for which, inter alia, there is or was substantial
authority for the treatment. Sec. 6662(d)(2)(B)(i). The
substantial authority standard is objective and involves an
analysis of the law and application of the law to relevant facts.
Sec. 1.6662-4(d)(2), Income Tax Regs. Substantial authority
exists for the tax treatment of an item where, considering all
relevant authorities, the weight of authorities supporting the
tax treatment of an item is substantial in relation to the weight
of authorities supporting contrary treatment. Antonides v.
Commissioner, 91 T.C. 686, 702 (1988), affd. 893 F.2d 656 (4th
Cir. 1990); sec. 1.6662-4(d)(3)(i), Income Tax Regs. The weight
accorded an authority depends on its relevance and
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