Cheng C. and Susan L. Kao, et al. - Page 8

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                  Section 6661(a), applicable to petitioners' 1988 tax year,                          
            provides for an addition to tax in the amount of 25 percent of                            
            the amount of any underpayment attributable to a substantial                              
            understatement.  The amount of the understatement generally is                            
            reduced by the portion of the understatement attributable to (1)                          
            the tax treatment of an item if there was substantial authority                           
            for such treatment, or (2) any item with respect to which the                             
            relevant facts affecting the item's tax treatment are adequately                          
            disclosed in the return or in a statement attached to the return.                         
            Sec. 6661(b)(2)(B).  The requirements of adequate disclosure can                          
            be satisfied by providing, on the return, information sufficient                          
            to enable the Commissioner to identify the potential controversy                          
            involved.  Schirmer v. Commissioner, 89 T.C. 277, 285-286 (1987).                         
                  Kolyn's 1988 return reported, on Schedule L, increases in                           
            Kolyn's long-term liabilities.  Petitioners contend that this                             
            information adequately disclosed the funds Kolyn received.  We                            
            conclude that the mere disclosure of an increase in long-term                             
            liabilities was insufficient to enable respondent to identify the                         
            potential controversy (i.e., whether petitioners failed to report                         
            income).  Accordingly, petitioners are liable for the section                             
            6661(a) additions to tax.                                                                 
                  C.  Accuracy-Related Penalties                                                      
                  Section 6662(a), applicable to petitioners' 1989 through                            
            1991 tax years, imposes an accuracy-related penalty in an amount                          
            equal to 20 percent of the portion of any underpayment to which                           




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