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          substantial understatement as an understatement of income tax for           
          the taxable year that exceeds the greater of 10 percent of the              
          tax required to be shown or $5,000.  Sec. 6662(d)(1).  We have              
          sustained respondent’s determinations of adjustments to                     
          petitioner’s income in their entirety in each of the tax years in           
          question; petitioner’s understatement of tax exceeds $5,000 and             
          10 percent of the tax required to be shown on his return.                   
               Respondent is foreclosed from imposing the accuracy-related            
          penalty if a taxpayer has substantial authority for the treatment           
          of the items at issue or if the taxpayer adequately disclosed               
          such items.  Sec. 6662(d)(2)(B)(i) and (ii).  Petitioner has the            
          burden of showing either that he had substantial authority for              
          the tax treatment of the tax certificate interest or that he                
          adequately disclosed his treatment on the returns for each year             
          in issue.  Rule 142(a).                                                     
               The substantial authority standard is “an objective standard           
          involving an analysis of the law and application of the law to              
          relevant facts.  The substantial authority standard is less                 
          stringent than the `more likely than not’ standard, * * * but               
               12(...continued)                                                       
                    (A) the amount shown as the tax by the                            
                    taxpayer on his return, plus                                      
                    (B) amounts not so shown previously                               
                    assessed (or collected without assessment),                       
                    over                                                              
                    (2) the amount of rebates made.                                   
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