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taxpayer had failed to mention the stepped-up basis anywhere in
the return. See id. at 684.
Like the taxpayers in Estate of Knox and Phinney, petitioner
has failed to provide enough information to allow an examining
agent to reasonably identify the underreporting of gain. In
order to qualify for relief under the adequate disclosure
exception to section 6229(c)(2), the disclosures on the return
have to be more directly related to the omitted income than what
was disclosed by petitioner.
We have considered all remaining arguments made by
petitioner for a result contrary to that expressed herein, and,
to the extent not discussed above, they are irrelevant or without
merit. Respondent’s motion for summary judgment will be granted,
and petitioner’s motion for summary judgment will be denied.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011