InterTAN, Inc. - Page 22

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          application of the law to relevant facts.  Sec. 1.6662-4(d)(2),             
          Income Tax Regs.  That standard is not so stringent that a                  
          taxpayer's treatment must be one that has a greater than                    
          50-percent likelihood of being sustained in litigation.  See id.            
          However, the substantial authority standard is more stringent               
          than the reasonable basis standard as defined in section 1.6662-            
          3(b)(3), Income Tax Regs.  Sec. 1.6662-4(d)(2), Income Tax Regs.            
          There may be substantial authority for more than one position               
          with respect to the same item.  Sec. 1.6662-4(d)(3)(i), Income              
          Tax Regs.                                                                   
               In order to satisfy the substantial authority standard of              
          section 6662(d)(2)(B)(i), a taxpayer must show that the weight of           
          the authorities supporting the tax return treatment of an item is           
          substantial in relation to the weight of authorities supporting             
          contrary treatment.  Antonides v. Commissioner, 91 T.C. 686, 702            
          (1988), affd. 893 F.2d 656 (4th Cir. 1990); sec.                            
          1.6662-4(d)(3)(i), Income Tax Regs.  All authorities relevant to            
          the tax treatment of an item, including the authorities contrary            
          to the treatment, are taken into account in determining whether             
          substantial authority exists.  Sec. 1.6662-4(d)(3)(i), Income Tax           
          Regs.  The weight of authorities is determined in light of the              
          pertinent facts and circumstances.  Id.  The weight accorded an             
          authority depends on its relevance and persuasiveness and the               
          type of document providing the authority.  Sec. 1.6662-                     

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