- 23 - to their CFC's are rejected, petitioners argue that because the relevant provisions of section 952 are so technical and unclear, it was not unreasonable for them to have adopted the interpretation they utilized in preparing and filing their 1990 joint Federal income tax return. Petitioners also argue that they satisfied the disclosure rules and provided sufficient information on their 1990 joint Federal income tax return regarding their CFC's to put respondent on notice of the basis for their claimed tax treatment of their subpart F income. We agree with respondent that no substantial authority existed to support petitioners' reading of section 952. With respect to disclosure, we agree with respondent that petitioners failed adequately to disclose facts necessary for respondent to determine the proper tax treatment of the subpart F income reported on petitioners' 1990 joint Federal income tax return. We sustain respondent's impositions of the addition to tax for petitioners' untimely filing of their 1990 joint Federal income tax return and the accuracy-related penalty. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
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