- 29 - adequate disclosure for purposes of section 6662. The Commissioner issued Rev. Proc. 91-19, 1991-1 C.B. 523, Rev. Proc. 92-23, 1992-1 C.B. 737, and Rev. Proc. 93-33, 1993-2 C.B. 470, listing categories of items for which disclosure on the return constitutes adequate disclosure for the 1990, 1991, and 1992 tax years. None of these revenue procedures lists tax-exempt interest income, which is at issue here. A taxpayer may also satisfy the requirements for adequate disclosure by providing sufficient information on the face of the return that enables the Commissioner to identify the potential controversy. Schirmer v. Commissioner, 89 T.C. 277, 285-286 (1987) (citing S. Rept. 97-494, at 274 (1982)); Elliott v. Commissioner, T.C. Memo. 1997-294; Horwich v. Commissioner, T.C. Memo. 1991-465. This method of disclosure requires more than a production of a "clue" with respect to the nature of the controversy. Horwich v. Commissioner, supra (citing Staff of the Joint Comm. on Taxation, General Explanation of the Revenue Provisions of the Tax Equity and Fiscal Responsibility Act of 1982, at 218 (J. Comm. Print 1982)). In the case at hand, the controversy concerning the interest income concerns whether tax certificates sold by a Florida county tax collector were obligations of a State or political subdivision thereof, making the interest paid thereon excludable from income under section 103. Petitioner's reporting of interest income on line 8b of his Form 1040 returns, entitledPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011