- 29 -
Adult Living Centers’ debts and legal fees incurred in defending
against those obligations.
The Commissioner, by annual revenue procedure (or
otherwise), may prescribe the circumstances under which
disclosure of information on a return in accordance with
applicable forms and instructions is adequate. See sec. 1.6662-
4(f)(2), (5), Income Tax Regs. The Commissioner issued Rev.
Proc. 92-23, 1992-1 C.B. 737, applicable to 1991 returns, and
Rev. Proc. 93-33, 1993-2 C.B. 470, which extended the application
of Rev. Proc. 92-23, 1992-1 C.B. 737, to 1992 returns. The
revenue procedures identify circumstances under which the
disclosure on a taxpayer's return of a position with respect to
an item is adequate disclosure for purposes of reducing the
understatement of income tax under section 6662.7
7Rev. Proc. 92-23, 1992-1 C.B. 737, 738, provides in part:
Additional disclosure of facts relevant to, or
positions taken with respect to, issues involving any
of the items set forth below is unnecessary for
purposes of reducing any understatement of income tax
under section 6662(d) of the Code provided that the
forms and attachments are completed in a clear manner
and in accordance with their instructions. The money
amounts entered on the forms must be verifiable, and
the information on the return must be disclosed in the
manner described below. For purposes of this revenue
procedure, a number is verifiable if, on audit, the
taxpayer can demonstrate the origin of the number (even
if that number is not ultimately accepted by the
Internal Revenue Service) and the taxpayer can show
good faith in entering that number on the applicable
(continued...)
Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: May 25, 2011