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chosen tax treatment was more likely than not the proper one.
Petitioner bears the burden of establishing that respondent's
determination was erroneous. Cluck v. Commissioner, 105 T.C.
324, 340 (1995).
Respondent determined that the understatement was
substantial. Petitioner does not dispute this point. Thus,
petitioner must establish that the understatement should be
reduced if he is to avoid imposition of the addition to tax for
substantial understatement.
Petitioner's sole argument is that he reasonably relied on
the agreement, which he implies constitutes substantial
authority. Petitioner, however, has not cited, nor have we
found, any authority that suggests that this agreement
constitutes substantial authority. Petitioner was not reasonable
in relying on the agreement for purposes of the addition to tax
for negligence, nor has he established that he reasonably
believed that taking the deductions relating to his 1983 tax
shelter investment was more likely than not correct.
Consequently, we conclude that petitioner is liable for the
addition to tax for substantial understatement.
We have considered petitioner's other arguments and found
them to be without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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