Estate of Helen G. Williamson - Page 8

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               In The Colony, Inc. v. Commissioner, 357 U.S. 28, 36 (1958)            
          (an income tax case), the Supreme Court, interpreting the meaning           
          of this statutory language, said:                                           
                    We think that in enacting section 275(c) [the                     
               predecessor of section 6501] Congress manifested no broader            
               purpose than to give the Commissioner an additional 2 [now             
               3] years to investigate tax returns in cases where, because            
               of a taxpayer's omission to report some taxable item, the              
               Commissioner is at a special disadvantage in detecting                 
               errors.  In such instances the return on its face provides             
               no clue to the existence of the omitted item.  On the other            
               hand, when, as here, the understatement of a tax arises from           
               an error in reporting an item disclosed on the face of the             
               return, the Commissioner is at no such disadvantage * * *.             
               This Court has interpreted the Supreme Court's "clue"                  
          standard to mean not "a detailed revelation of each and every               
          underlying fact", but also that it "does not simply mean a 'clue'           
          which would be sufficient to intrigue a Sherlock Holmes."  Quick            
          Trust v. Commissioner, 54 T.C. 1336, 1347 (1970), affd. 444 F.2d            
          90 (8th Cir. 1971).  Furthermore, in interpreting this statutory            
          language (common to both income and estate tax provisions) in               
          section 6501(e), relating to the omission as "disclosed in the              
          return, or in a statement attached to the return, in a manner               
          adequate to apprise the Secretary of the nature and amount of               
          such item", we have held that disclosure of the omitted material            
          is adequate, even without disclosing exact dollar amounts.  Quick           
          Trust v. Commissioner, supra; University Country Club, Inc. v.              
          Commissioner, 64 T.C. 460, 470 (1975); Morris v. Commissioner,              
          T.C. Memo. 1966-245.  The disclosure statement however must be              
          sufficiently detailed so that a decision whether to select the              




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