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was substantial authority, or with respect to which the relevant
facts affecting its treatment were adequately disclosed on the
return or in a statement attached thereto. Sec. 6661(b)(2)(A)
and (B).
Petitioner makes no argument that there was adequate
disclosure. Likewise, petitioner has not produced substantial
authority for the treatment of these items. Petitioner's claim
that he reasonably and in good faith relied on the advice of his
accountant in claiming such items, without evidence of what
authority Mr. Coscia relied upon in determining the treatment of
such items, is insufficient to show substantial authority. See
Buck v. Commissioner, T.C. Memo. 1997-191. "Authority" for this
purpose includes statutes or regulatory provisions, court
decisions, administrative pronouncements, tax treaties, or
legislative history. Sec. 1.6661-3(b)(2), Income Tax Regs.
Opinions rendered by tax professionals are not substantial
authority.3 Id.
In the instant case the deficiency upon which the additions
to tax were imposed equals $9,549. The amount of tax required to
be shown on the return pursuant to the previous partnership
proceedings is $13,735. Thus, the understatement ($9,549) is
3 Because we conclude that petitioner has not made adequate
disclosure or produced substantial authority, it is unnecessary
for us to consider whether petitioner's investment in Ridge
Energy is a "tax shelter" within the meaning of sec.
6661(b)(2)(C).
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