- 48 - the tax treatment of the item (or items). (2) Disclosure of legal issue. In lieu of setting forth the facts affecting the tax treat- ment of an item (or group of similar items) in accordance with paragraph (b)(1)(iv) of this section, the taxpayer may set forth a concise description of the legal issue presented by such facts. (3) Requirement of particularity. Disclosure is not adequate with respect to an item (or group of similar items) if it consists of undifferentiated information that is not arranged in a manner that reasonably may be expected to apprise the Internal Revenue Service of the identity of the item, its amount, and the nature of the potential controversy concerning the item (or items). For example, attachment to the return of an acquisition agreement generally will not constitute adequate disclosure of the issues involved in determining the basis of certain acquired assets. (c) Disclosure on return. The Commissioner may by revenue procedure prescribe the circum- stances in which information provided on the return in accordance with the applicable forms and instructions will be adequate disclosure for purposes of section 6661. We agree with respondent that petitioner has not established that the understatement for any of the years in issue should be reduced pursuant to section 6662(d)(2)(B)(ii) with respect to the portion of the understatement attributable to the personal holding company tax. A review of each of petitioner's returns for 1989 through 1993 might cause the reviewer to wonder about the application of personal holding company tax, but it wouldPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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