S. Victoria Wells - Page 14

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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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