Char-Lil Corporation - Page 44

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             return.  See Rev. Proc. 89-11, 1989-1 C.B. 797; Rev. Proc.               
             90-16, 1990-1 C.B. 477; Rev. Proc. 91-19, 1991-1 C.B. 523;               
             Rev. Proc. 92-23, 1992-1 C.B. 737; Rev. Proc. 93-33, 1993-2              
             C.B. 470; Rev. Proc. 94-36, 1994-1 C.B. 682; Rev. Proc. 94-              
             74, 1994-2 C.B. 823.                                                     
                  Before the 1993 amendment, section 6662(d)(2)(B)(ii)                
             provided as follows:                                                     

                       (B) Reduction for understatement due to                        
                  position of taxpayer or disclosed item.-- The                       
                  amount of the understatement under subparagraph                     
                  (A) shall be reduced by that portion of the                         
                  understatement which is attributable to--                           
                            *   *   *   *   *   *   *                                 
                            (ii) any item with respect to                             
                       which the relevant facts affecting the                         
                       item's tax treatment are adequately                            
                       disclosed in the return or in a                                
                       statement attached to the return.                              

             Thus, for tax years 1989 through and including 1992, the                 
             statute did not impose the reasonable basis requirement.                 
             However, regulations promulgated under section 6662 to                   
             implement the adequate disclosure exception, former section              
             1.6662-4(e) and (f), Income Tax Regs., provided as follows:              

                       (e) Disclosure of certain information--                        
                  (1) Effect of adequate disclosure.  Items for                       
                  which there is adequate disclosure as provided                      
                  in this paragraph (e) and in paragraph (f) of                       
                  this section are treated as if such items were                      
                  shown properly on the return for the taxable year                   
                  in computing the amount of the tax shown on the                     
                  return.  Thus, for purposes of section 6662(d),                     



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