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that is actually shown on the return. Sec. 6662(d)(2)(A). An
understatement is "substantial" if the amount exceeds the greater
of 10 percent of the tax required to be shown on the return or
$5,000. Sec. 6662(d)(1)(A). Petitioner's omission from his tax
return of insurance renewal commissions in the amount of $113,081
results in a substantial understatement.
Petitioner may avoid liability for the accuracy-related
penalty in either of two ways. First, if there is or was
substantial authority for petitioner's tax treatment of any
portion of the understatement, that portion would be excluded
from the penalty computation. Sec. 6662(d)(2)(B)(i).
To determine whether the treatment is supported by
substantial authority, the weight of the authorities in support
of petitioner's position must be substantial in relation to the
weight of the authorities supporting contrary positions.
Antonides v. Commissioner, 91 T.C. 686, 700-704 (1988), affd. 893
F.2d 656 (4th Cir. 1990); sec. 1.6662-4(d)(3), Income Tax Regs.
There are no authorities that support petitioner's treatment.
Indeed, the weight of the authorities, discussed supra, clearly
rejects petitioner's treatment of the renewal commissions. Thus,
petitioner does not qualify under this exception.
Second, petitioner's liability could be reduced if
petitioner had adequately disclosed the relevant facts on his tax
return and there was a reasonable basis for the treatment of the
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