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show that substantial authority existed for the tax treatment of
the Blythe I loss on his 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
petitioner did not attach a statement to his 1982 return
disclosing the specific facts surrounding the Blythe I 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
sufficient information is provided to enable respondent to
identify the potential controversy involved. Schirmer v.
Commissioner, 89 T.C. 277, 285-286 (1987). However, a mere
claiming of the loss, without further explanation, is not
sufficient to alert respondent to the controversial section 174
deduction of which the partnership loss consisted. Petitioner
has failed to show that the relevant facts pertaining to his
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