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Sec. 6661(b)(1)(A). Petitioner bears the burden of proving
that imposition of the addition to tax under section 6661 is
erroneous. Rule 142(a); Tweeddale v. Commissioner, 92 T.C. 501,
506 (1989).
If a taxpayer has substantial authority for the
tax treatment of any item on the return, the understatement
is reduced by the amount attributable to it. Sec.
6661(b)(2)(B)(i). Similarly, the amount of the understatement
is reduced for any item adequately disclosed either on the
taxpayer's return or in a statement attached to the return.
Sec. 6661(b)(2)(B)(ii). A taxpayer’s position may be adequately
disclosed either in a statement attached to the tax return, or
on the tax return itself. Id. Respondent contends that
petitioner did not have substantial authority for her position
but does not deny that she adequately disclosed the casualty loss
on her 1985, 1986, and 1987 returns. We consider whether
petitioner adequately disclosed her position on her 1985, 1986,
and 1987 returns.
Disclosure can be accomplished under section 6661 by
providing sufficient information on the tax return to enable the
Commissioner to identify the potential controversy. Schirmer v.
Commissioner, 89 T.C. 277, 285-286 (1987).
The Commissioner may promulgate revenue procedures which
prescribe the circumstances in which information provided on a
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