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to be shown for the taxable year or $5,000. Secs.
6661(b)(1)(A), 6662(d)(1)(A). In determining whether there
is a substantial understatement of liability, the amount
of an understatement is reduced by any portion attributable
to the tax treatment of an item for which the taxpayer had
substantial authority, and by any item with respect to
which the relevant facts affecting the taxpayer's treat-
ment are adequately disclosed in the return or in a
statement attached to the return. Secs. 6661(b)(2)(B),
6662(d)(2)(B).
Petitioners bear the burden of proving that
respondent's imposition of an addition to tax under section
6661 or penalty under section 6662 is erroneous. See Rule
142(a); Luman v. Commissioner, 79 T.C. 846, 860 (1982).
Petitioners also bear the burden of proving that they had
substantial authority for omitting an item from their
return. See Tippin v. Commissioner, 104 T.C. 518, 535
(1995).
We find that petitioners have failed to satisfy their
burden of proving that respondent's imposition of the
addition to tax under section 6661 and penalty under
section 6662 is erroneous in this case. Petitioners
offered no authority for their position that the items
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