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likely than not proper. Sec. 6661(b)(2)(C)(i)(II). Second,
disclosure, whether or not adequate, will not reduce the amount
of the understatement. Sec. 6661(b)(2)(C)(i)(I).
Substantial authority exists when "the weight of the
authorities supporting the treatment is substantial in relation
to the weight of authorities supporting contrary positions." See
sec. 1.6661-3(b)(1), Income Tax Regs. Petitioners have failed to
show that substantial authority existed for the tax treatment of
the Blythe II loss on their 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. Sec. 1.6661-
4(b) and (c), Income Tax Regs. The record indicates that
petitioners did not attach a statement to their 1982 return
disclosing the specific facts surrounding their Blythe II loss
deduction. Rev. Proc. 83-21, supra, applicable to tax returns
filed in 1983, lists information that would be deemed sufficient
disclosure if listed on the return itself, without the necessity
of attaching an additional statement to the return. However,
none of the specific tax items referenced in Rev. Proc. 83-21,
supra, are relevant to the instant case. If disclosure is not
made in compliance with the regulations or the revenue procedure,
adequate disclosure on the return may still be satisfied if
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