- 26 -
1986 amended return or its attachments. However, a disclosure
need not do so if, as here, it clearly puts the Commissioner on
notice of the possible controversy. See Schirmer v.
Commissioner, 89 T.C. 277, 285-286 (1987); Mitchell v.
Commissioner, T.C. Memo. 1994-237, affd. 73 F.3d 628 (6th Cir.
1996).
We conclude that petitioner is not liable for the addition
to tax under section 6661(a) for 1988 and for the accuracy-
related penalty under section 6662(a) and (b)(2) for 1989 for
substantial understatement of tax.
Decisions will be
entered under Rule 155.
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Last modified: May 25, 2011