Steven K. Han - Page 19





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          there is substantial authority for that treatment, or if relevant           
          facts affecting the item’s tax treatment are adequately disclosed           
          in the return.  Sec. 6661(b)(2)(B).                                         
               Petitioner contends merely that the addition to tax for                
          substantial understatement of tax is computational and will not             
          apply if we accept his arguments relating to the issues involved            
          in the instant case.  Thus, petitioner provided no evidence that            
          he had substantial authority for the understatement, and his tax            
          return did not disclose the relevant facts sufficient to enable             
          respondent to identify the potential controversy involved.                  
          Schirmer v. Commissioner, 89 T.C. 277, 285-286 (1987).                      
          Respondent presented evidence at trial through testimony of                 
          witnesses and documents and through the concessions at trial and            
          in the briefs, sufficient to meet the burden of proving certain             
          increased deficiencies raised in the amendment to answer to                 
          amendment to petition.  Accordingly, we sustain respondent as to            
          the imposition of the addition to tax for substantial                       
          understatement of income tax.                                               
               To reflect the foregoing,                                              
          Decision will be entered                                                    
          under Rule 155.                                                             
                                                                                     








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