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With respect to all amounts in the fourth column, respondent
contends on brief that there was no substantiation. Petitioner
has offered no explanation with respect to the amounts he
concedes were claimed improperly. In the absence of any
substantiation for these amounts, we find that the underpayment
arising from their disallowance is attributable to negligence.
Sec. 1.6662-3(b)(1), Income Tax Regs.
Substantial Understatement of Tax
Alternatively, respondent determined that the accuracy-
related penalty applies due to a substantial understatement of
income tax pursuant to section 6662(b)(2). Section 6662(d)(1)(A)
provides that a substantial understatement occurs when the
understatement (of tax) exceeds the greater of $5,000 or 10
percent of the amount of tax required to be shown on the return.
Generally, the understatement is the amount of tax required to be
shown on the return over the amount of tax imposed which is shown
on the return, reduced by that portion of the understatement
attributable to: (i) The tax treatment of an item for which
there was substantial authority; or, (ii) an item with respect to
which the relevant facts affecting its treatment were adequately
disclosed on the return or in a statement attached thereto. Sec.
6662(d)(2)(A) and (B). Petitioner has not provided any authority
for the positions taken on his returns. Petitioner argues for
relief from penalties because he made full disclosure (when
audited) of all the facts and circumstances surrounding the
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