Char-Lil Corporation - Page 47

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                  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-cerning                         




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Last modified: May 25, 2011