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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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