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the items in issue were attributable to other taxpayers. Indeed,
the alternate payees did not report--or even disclose--these
items on their income tax returns for the years in question.
Furthermore, the evidence in the record leaves no doubt that
petitioner exercised dominion and control over those items of
income when they were deposited into Mrs. Hernandez’ bank
account. The Supreme Court’s pronouncement in Commissioner v.
Glenshaw Glass Co., supra, has made it axiomatic that items over
which a taxpayer has dominion and control are attributable to him
and must therefore be included in income. Petitioner had no
substantial authority for failing to include items of tax
certificate interest income on his tax returns for the tax years
in question.
Neither did petitioner adequately disclose his position
regarding the treatment of tax certificate interest income. A
taxpayer's position may be adequately disclosed either on the
return or on a statement attached to the return. Sec.
6662(d)(2)(B)(ii). Petitioner did not attach a statement to his
tax returns for the 1990, 1991, and 1992 tax years explaining his
position regarding the tax certificate interest income. We
therefore examine whether petitioner adequately disclosed his
position on his tax returns.
Section 1.6662-4(f)(2), Income Tax Regs., provides that the
Commissioner may by revenue procedure prescribe the circumstances
under which information provided on the return will constitute
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