- 45 -                                         
          amount of tax shown in such return, see sec. 6662(d)(2)(A), and             
          is substantial in the case of an individual if the amount of the            
          understatement for the taxable year exceeds the greater of 10               
          percent of the tax required to be shown in the tax return for               
          that year or $5,000, see sec. 6662(d)(1)(A).                                
               The amount of the understatement is reduced to the extent              
          that it is attributable to, inter alia, an item for which there             
          is or was substantial authority.  See sec. 6662(d)(2)(B)(i).  In            
          order to satisfy the substantial authority standard of section              
          6662(d)(2)(B)(i), a taxpayer must show that the weight of the               
          authorities supporting the tax return treatment of an item is               
          substantial in relation to the weight of authorities supporting             
          contrary treatment.  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           
          authority for a position even where it is supported only by a               
          well-reasoned construction of the pertinent statutory provision             
          as applied to the relevant facts.  See sec. 1.6662-4(d)(3)(ii),             
          Income Tax Regs.  There may be substantial authority for more               
          than one position with respect to the same item.  See sec.                  
          1.6662-4(d)(3)(i), Income Tax Regs.                                         
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