- 47 - which there is adequate disclosure are treated as if such items were shown properly on the return for the taxable year in computing the amount of tax for purposes of section 6661, shown on the return. Thus, the tax attributable to such items is not included in the understatement for the year. (See paragraph (d)(2) of � 1.6661-2.) Disclosure is adequate with respect to the tax treatment of an item on a return only if it is made on such return or in a statement attached thereto. Thus, disclosure with respect to a recurring item, such as the basis of recovery property, made on a return or statement attached thereto for one taxable year is not adequate disclosure with respect to the item for any other taxable year. See paragraph (d) of this section for special rules relating to disclosure with respect to carrybacks and carryovers. (b) Disclosure in attached statement-- (1) In general. Disclosure will be adequate with respect to an item (or group of similar items, such as the specific deduction of business bad debts or the deduction of amounts paid or incurred for supplies by a taxpayer engaged in business), if it is made on a properly completed Form 8275 or if it takes the form of a statement attached to the return that includes the following: (i) A caption identifying the statement as disclosure under section 6661. (ii) An identification of the item (or group of similar items) with respect to which disclosure is made. (iii) The amount of the item (or group of similar items). (iv) The facts affecting the tax treatment of the item (or group of similar items) that reasonably may be expected to apprise the Internal Revenue Service of the nature of the potential controversy con-cerningPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
Last modified: May 25, 2011