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to the return". Next, we must decide whether petitioner
adequately disclosed her tax position. The statute does not
prescribe what constitutes adequate disclosure of relevant facts.
Schirmer v. Commissioner, 89 T.C. 277, 285 (1987).
This Court has indicated that a taxpayer may satisfy the
requirements of adequate disclosure for purposes of section 6662
if he provides sufficient facts on the face of his return that
enable the Commissioner to identify the potential controversy
involved. Id. at 286. We hold that petitioner has satisfied the
adequate disclosure requirement.
Petitioner disclosed on her 1989 Federal income tax return
the sale of the Paddock Lane property and reported long-term
capital gain. She sold the property for $630,000 and reported
$58,933 in expenses related to the sale. Consequently, the total
amount realized was $571,067. Petitioner reported a basis of
$560,868 which, offset against the amount realized, generated a
gain of $10,199 on the sale of the Paddock Lane property.
Furthermore, petitioner reported she did not intend to utilize
the section 1034 basis rollover provision. Petitioner did not
disclose any further information about the sale of the Paddock
Lane property. It is likely that the large basis of the Paddock
Lane property resulting in a small long-term capital gain
generated respondent's audit. The information reported was
sufficient to apprise respondent of, or to enable respondent to
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