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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.
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