- 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 Next
Last modified: May 25, 2011