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understatement which is attributable to the tax treatment of any
item by the taxpayer if there is or was substantial authority for
such treatment or the relevant facts affecting the item's tax
treatment are adequately disclosed in the return or in a
statement attached thereto. See sec. 6661(b)(2)(B). With
respect to tax shelters, the understatement is reduced only if
the taxpayer establishes that he reasonably believed that the tax
treatment of such item by the taxpayer was more likely than not
the proper treatment. See sec. 6661(b)(2)(C)(i). The term "tax
shelter" includes a partnership or any other plan or arrangement
if the principal purpose of such partnership, entity, plan, or
arrangement is the avoidance or evasion of Federal income tax.
Sec. 6661(b)(2)(C)(ii).
In notices of deficiency for 1982 through 1984 and 1986
through 1988, respondent determined that the Kanters' entire
underpayment for each year was a substantial understatement
within the meaning of section 6661. Respondent's determination
is presumed correct. Kanter had the burden of proving that
respondent's determination was erroneous. He failed to do so.
In amendments to answers for 1982 through 1984 and 1986
through 1988, respondent asserted the section 6661 addition to
tax with respect to any underpayments of tax arising from
unreported income not included in the notices of deficiency.
Respondent had the burden of proof to the extent that the section
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