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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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