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sec. 8002, 100 Stat. 1951, provides for an addition to tax of 25
percent of the amount of any underpayment attributable to a
substantial understatement of income tax for the taxable year. A
substantial understatement of income tax exists if the amount of
the understatement exceeds the greater of 10 percent of the tax
required to be shown on the return, or $5,000. Sec.
6661(b)(1)(A). Generally, the amount of an understatement is
reduced by the portion of the understatement that the taxpayer
shows is attributable to either (1) the tax treatment of any item
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. 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. 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."
Sec. 1.6661-3(b)(1), Income Tax Regs. Petitioner has failed to
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