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of tax shown on the taxpayer's return is less than the amount
required to be shown on the return. Sec. 6661(b)(2)(A). In the
case of individuals, an understatement is substantial if it
exceeds the greater of $5,000 or 10 percent of the tax required
to be shown. Sec. 6661(b)(1)(A). The amount of the
understatement may be reduced under section 6661(b)(2)(B) for
amounts adequately disclosed or supported by substantial
authority. Respondent's determination of the addition to tax is
presumed correct, and petitioner must prove otherwise. Rule
142(a); Hall v. Commissioner, 729 F.2d 632, 635 (9th Cir. 1984),
affg. T.C. Memo. 1982-337; Bixby v. Commissioner, supra at 791-
792.
Respondent determined that petitioners Heller and Murphy are
liable for an accuracy-related penalty for a substantial
understatement of income tax under section 6662 for the entire
underpayments for their 1989 taxable year. Section 6662(a)
imposes a penalty equal to 20 percent of the portion of the
underpayment that is attributable to a substantial understatement
of income tax.
Petitioners argue that substantial authority supports their
respective positions. Substantial authority exists for the tax
treatment of an item only if the weight of the authorities
supporting the treatment is substantial in relation to the weight
of the authorities supporting contrary positions. Accardo v.
Commissioner, 942 F.2d 444, 453 (7th. Cir. 1991), affg. 94 T.C.
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