Be sure to supply all the information for Parts I, II and, if
applicable, Part III. Your disclosure will be considered adequate if
you file Form 8275 and supply the information requested in detail.
Use Part IV on Page 2 if you need more space for Part I or II.
Indicate the corresponding part and line number from page 1. You may
use a continuation sheet(s) if you need additional space. Be sure to
put your name and identifying number on each sheet.
Column (a).
If you are disclosing a position contrary to a rule (such as a
statutory position or IRS revenue ruling), you must identify the rule
in column (a).
Column (b).
Identify the item by name.
If any item you disclose is from a pass-through entity, you must
identify the item as such. If you disclose items from more than one
pass-through entity, you must complete a separate Form 8275 for each
entity. Also, see
How To File on page 1.
Column (c).
Enter a complete description of the item(s) you are disclosing.
Example.
If entertainment expenses were reported in column (b),
then list in column (c) “theater tickets, catering
expenses, and banquet hall rentals.”
If you claim the same tax treatment for a group of similar items in
the same tax year, enter a description identifying the group of items
you are disclosing rather than a separate description of each item
within the group.
Columns (d) through (f).
Enter the location of the item(s) by identifying the form number or
schedule and the line number in
columns (d) and
(e)
and the amount of the item(s) in
column (f).
Your disclosure must include:
- A description of the relevant facts and the nature of the
controversy affecting the tax treatment of the item or
- A concise description of the legal issues presented by these
facts.
Note.
Disclosure will not be considered adequate unless 1 and
2 above are provided using Form 8275. For example, your
disclosure will not be considered adequate if you attach a copy of an
acquisition agreement to your tax return to disclose the issues
involved in determining the basis of certain acquired assets. Also, If
Form 8275 is not completed and attached to the return, the disclosure
will not be considered valid even if the information in 1
and 2 above is provided.
Line 4.
Contact your pass-through entity if you do not know where its
return was filed. However, for partners and S corporation
shareholders, information for line 4 can be found on the Schedule K-1
that you received from the partnership or S corporation.
