William J. Fleischaker and Donni L. Fleischaker - Page 29

                                        - 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                    

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