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"Tax-exempt interest income", did not provide respondent with any
clue that there was a potential controversy. The inclusion of
the amounts on line 8b, indicating petitioner's position that the
amounts set forth were exempt under section 103, did not do the
job. Identification of the correct section of the Code to
support a reported position does not, without more, provide
sufficient information to enable the Commissioner to identify the
potential controversy. Elliott v. Commissioner, supra.
For the foregoing reasons, we find that petitioner neither
had substantial authority nor provided adequate disclosure of his
position for the treatment of the items at issue. Accordingly,
we hold petitioner liable for accuracy-related penalties for
substantial understatements of income tax under section 6662.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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