Char-Lil Corporation - Page 50

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             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.                               



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