Don L. and Lora Christensen - Page 21




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          likely than not proper.  Sec. 6661(b)(2)(C)(i)(II).  Second,                
          disclosure, whether or not adequate, will not reduce the amount             
          of the understatement.  Sec. 6661(b)(2)(C)(i)(I).                           
               Substantial authority exists when "the weight of the                   
          authorities supporting the treatment is substantial in relation             
          to the weight of authorities supporting contrary positions."  See           
          sec. 1.6661-3(b)(1), Income Tax Regs.  Petitioners have failed to           
          show that substantial authority existed for the tax treatment of            
          the Blythe II loss on their 1982 return.                                    
               Adequate disclosure of the tax treatment of a particular               
          item may be made either in a statement attached to the return, or           
          on the return itself, if it is in accordance with the                       
          requirements of Rev. Proc. 83-21, 1983-1 C.B. 680.  Sec. 1.6661-            
          4(b) and (c), Income Tax Regs.  The record indicates that                   
          petitioners did not attach a statement to their 1982 return                 
          disclosing the specific facts surrounding their Blythe II loss              
          deduction.  Rev. Proc. 83-21, supra, applicable to tax returns              
          filed in 1983, lists information that would be deemed sufficient            
          disclosure if listed on the return itself, without the necessity            
          of attaching an additional statement to the return.  However,               
          none of the specific tax items referenced in Rev. Proc. 83-21,              
          supra, are relevant to the instant case.  If disclosure is not              
          made in compliance with the regulations or the revenue procedure,           
          adequate disclosure on the return may still be satisfied if                 





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