Eric B. Benson, et al. - Page 30

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          We held that the Bensons received additional dividend income of             
          $1,072 in 1994 because “Despite the fact that Eric reported the             
          amount credited on his 1994 return, the dividends are clearly               
          attributable to the Bensons and should have been reported by                
          them.”  Id.  We find that the disclosure of the 1994 Franklin               
          dividend on the return of Eric Benson, the Bensons’ son, does not           
          satisfy the disclosure requirement of section 6501(e)(1)(A)(ii).            
          See Greenway v. Commissioner, T.C. Memo. 1987-4 (“Reporting of              
          that income on their children’s returns, and petitioners payment            
          of taxes owed on it, does not satisfy the section                           
          6501(e)(1)(A)(ii) requirement that the omission be ‘disclosed in            
          the return, or in a statement attached to the return, in a manner           
          adequate to apprise the Secretary of the nature and amount of               
          such item.’”).                                                              
               For purposes of applying section 6501(e), we hold that the             
          Bensons’ omitted gross income in 1994 equals $337,092, which is             
          itemized as follows:                                                        
               Items of omitted                   Amounts omitted                     
                 gross income                      by the Bensons                     
               ERG recreation fund payments            $2,698                         
               Alice Lane--property taxes              8,196                          
               Automobile expenses      14,723                                        
               Director’s fees                    37,000                              
               Esther Benson check                12,000                              
               Townsend check                15,000                                   
               Travel expenses                        3,889                          
               Legal expenses                         4,033                          
               Employee relation’s expenses              3,035                        
               Education expenses                      9,166                          
               Life insurance                          4,781                          

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