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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. Petitioners have failed to
present evidence 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,
disclosure on the return may still be adequate if sufficient
information is provided to enable the Commissioner to identify
the potential controversy involved. Schirmer v. Commissioner, 89
T.C. 277, 285-286 (1987). The mere claiming of the loss,
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