13 discussion reflects, the decided cases have rejected the position maintained by petitioner herein. Petitioners also argue that they adequately disclosed the relevant facts relating to the transactions on their return. Two types of disclosure are provided for: (1) Disclosure in statements attached to the return, sec. 1.6661-4(b), Income Tax Regs., and (2) disclosure on the return, sec. 1.6661-4(c), Income Tax Regs. Petitioners did not attach any statement to their return; therefore, section 1.6661-4(b), Income Tax Regs., is not applicable. Taxpayers can meet the requirements of adequate disclosure by providing on the return sufficient information to enable respondent to identify the potential controversy involved. Crown Income Charitable Fund v. Commissioner, 98 T.C. 327, 340 (1992), affd. 8 F.3d 571 (7th Cir. 1993); Schirmer v. Commissioner, supra at 285-286. Petitioners did not indicate anywhere on their return for 1987 that they had entered into the assumption agreement or the nature of the underlying indebtedness. Petitioners simply reported the losses of ABDC and the income of GCC. This, without more, does not amount to sufficient information to meet the adequate disclosure standard. See Schirmer v. Commissioner, supra at 286.7 7 See also Wilson v. Commissioner, T.C. Memo. 1991-544, where we sustained respondent's determination under sec. 6661 on the basis of lack of disclosure and lack of substantial authority.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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