Domingo A. Lopez - Page 21




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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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