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for which there was substantial authority, or (2) the tax
treatment of any item with respect to which the relevant facts
were adequately disclosed on the return. See sec. 6661(b)(2)(B).
If an understatement is attributable to a tax shelter item,
however, different standards apply. First, in addition to
showing the existence of substantial authority, a taxpayer must
show that he reasonably believed that the tax treatment claimed
was more likely than not proper. See sec. 6661(b)(2)(C)(i)(II).
Second, disclosure, whether or not adequate, will not reduce the
amount of the understatement. See sec. 6661(b)(2)(C)(i)(I).
Substantial authority exists when "the weight of authorities
supporting the treatment is substantial in relation to the weight
of the authorities supporting contrary positions." See sec.
1.6661-3(b)(1), Income Tax Regs. Petitioner has failed to
present evidence to show that substantial authority existed for
the tax treatment of the Utah I loss on his 1982 return.
Adequate disclosure of the tax treatment of a particular
item may be made either in a statement attached to the return or
on the return itself, if it is in accordance with the
requirements of Rev. Proc. 83-21, 1983-1 C.B. 680. See sec.
1.6661-4(b) and (c), Income Tax Regs. The record indicates that
petitioner did not attach a statement to his 1982 return
disclosing the specific facts surrounding his Utah I loss
deduction. Rev. Proc. 83-21, supra, applicable to tax returns
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