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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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