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tax returns"; and (3) "there is a sufficient, uncontroverted
basis in the record to conclude that Petitioners relied in good
faith on Petitioners' professional return preparer, C.P.A.
Clarence Riggs, in taking the positions on Petitioners' returns".
Section 6662(a) imposes an accuracy-related penalty equal to
20 percent of the underpayment of tax resulting from a substan-
tial understatement of income tax. An understatement is equal to
the excess of the amount of tax required to be shown in the tax
return over the amount of tax shown in the tax return, see sec.
6662(d)(2)(A), and is substantial in the case of a corporation if
it exceeds the greater of 10 percent of the tax required to be
shown or $10,000, see sec. 6662(d)(1)(A) and (B).
The amount of the understatement is reduced to the extent
that it is attributable to an item for which there was substan-
tial authority. See sec. 6662(d)(2)(B)(i). In order to satisfy
the substantial authority standard of section 6662(d)(2)(B)(i),
petitioners must show that the weight of authorities supporting
their position is substantial in relation to those supporting a
contrary position. See Antonides v. Commissioner, 91 T.C. 686,
702 (1988), affd. 893 F.2d 656 (4th Cir. 1990); sec. 1.6662-
4(d)(3)(i), Income Tax Regs. The substantial authority standard
is not so stringent that a taxpayer's treatment must be one that
is ultimately upheld in litigation or that has a greater than 50-
percent likelihood of being sustained in litigation. See sec.
1.6662-4(d)(2), Income Tax Regs. A taxpayer may have substantial
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