Robert A. Stanford and Susan Stanford - Page 23

                                       - 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               
               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  

Last modified: May 25, 2011