Generally, in applying transitional relief for income tax returns, amended returns or refund claims, disclosure would be adequate if made on a Form 8275, Disclosure Statement, or
Form 8275-R, Regulation Disclosure Statement, attached to the return, amended return, or refund claim, or pursuant to the annual revenue procedure authorized in Treas.
The penalty for negligence or disregard of rules or regulations is not imposed if the taxpayer adequately discloses his or her position on Form 8275 ("Disclosure Statement"), or
Form 8275-R ("Regulation Disclosure Statement") for a "good faith" challenge to a regulation, and attaches it to the return or a qualified amended return.
The new
Form 8275-R must be attached to any return that takes a position contrary to IRS regulations.
In the case of an item or position that is not contrary to a regulation., disclosure must be made on Form 8275; however, a position or item contrary to a regulation must be disclosed on
Form 8275-R, Regulation Disclosure Statement (Regs.
A taxpayer's position is adequately disclosed if made on Form 8275 (or, in the case of a position contrary to a regulation, on
Form 8275-R (75)) and attached to the taxpayer's return or qualified amended return.
As a result, the IRS issued guidance (see REG-129243-07 and Notice 2008-13) that softened the impact of the new standard by allowing preparers to avoid application of the standard in some situations where a preparer provided the taxpayer a properly completed Form 8275, Disclosure Statement, or
Form 8275-R, Regulation Disclosure Statement, for the position or disclosed certain information to the taxpayer about the position.
Should a preparer decide that his or her student client has met the half support from earned income requirement, he or she should consider the need to include a Form 8275, Disclosure Statement, or
Form 8275-R, Regulation Disclosure Statement, regarding Temp.
Disclosure may be made on Form 8275, Disclosure Statement, or
Form 8275-R, Regulation Disclosure Statement, or on the return itself in accordance with the annual revenue procedure (Rev.
For these purposes, disclosure generally is made on Form 8275, Disclosure Statement, or
Form 8275-R, Regulation Disclosure Statement.
Attached to the Federal estate tax return was
Form 8275-R, Regulation Disclosure Statement, in which the estate took the position that Regs.
If the information provided does not so apprise the Service, a Form 8275 or
Form 8275-R must be used to adequately disclose the item (see Part II of the instructions for those forms).
He also filed
Form 8275-R, Regulation Disclosure Statement, disclosing that he relied on then-pending proposed legislation (HR 2794, 107th Cong., 2d Sess.