- 50 - See sec. 1.6662-4(f), Income Tax Regs., and former sec. 1.6661-4, Income Tax Regs. As to these years, petitioner claims that sufficient information was set forth in each of the returns to constitute adequate disclosure of its liability for personal holding company tax. The governing regulations, however, require explicit and detailed disclosure in order for the disclosure to be considered adequate. Sec. 1.6662-4(f), Income Tax Regs.; former sec. 1.6661-4(b), Income Tax Regs. Petitioner fails to make any reference to the operative regulations. Petitioner does not explain how the purported disclosures on each of the returns for 1989 through 1993 satisfy the requirements of the regulations, nor does petitioner present any reason to conclude that the regulations do not apply. Petitioner's 1994 return contains a Schedule PH, U.S. Personal Holding Company (PHC) Tax, and other information explicitly setting forth petitioner's position that it is not subject to personal holding company tax. Even accept- ing petitioner's position that the attachments to its 1994 return constitute adequate disclosure under section 6662(d)(2)(B)(ii), petitioner has made no attempt to show that it had a "reasonable basis" for that position. Upon consideration of the foregoing, Decision will be entered under Rule 155.Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50
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