- 108 - 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.Page: Previous 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108
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