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Respondent acknowledges that respondent has the burden of
production under section 7491(c) with respect to the accuracy-
related penalty under section 6662(a). To meet that burden,
respondent must come forward with sufficient evidence showing
that it is appropriate to impose the accuracy-related penalty.
Higbee v. Commissioner, 116 T.C. 438, 446 (2001).
Section 6662(a) imposes an accuracy-related penalty equal to
20 percent of the underpayment of tax attributable to, inter
alia, a substantial understatement of tax, sec. 6662(b)(2). An
understatement is equal to the excess of the amount of tax
required to be shown in the tax return over the amount of tax
shown in the tax return, sec. 6662(d)(2)(A), and is substantial
in the case of an individual if it exceeds the greater of 10
percent of the tax required to be shown or $5,000, sec.
6662(d)(1)(A).
The amount of the understatement shall be reduced to the
extent that it is attributable to, inter alia, the tax treatment
of an item for which there is or was substantial authority. See
sec. 6662(d)(2)(B)(i). In order to satisfy the substantial
authority standard of section 6662(d)(2)(B)(i), petitioners must
show that the weight of authorities supporting their tax return
position is substantial in relation to those supporting a con-
trary position. See Antonides v. Commissioner, 91 T.C. 686, 702
(1988), affd. 893 F.2d 656 (4th Cir. 1990). That standard is not
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