John R. Hernandez - Page 29

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          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, entitled               



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