Be sure to supply all of the information requested in Parts I and II and, if applicable, Part III. Your disclosure will be
considered adequate if
you file Form 8275-R 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).
Enter a detailed citation for each regulation for which you have taken a contrary position.
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-R 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 an entertainment expense was 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; and
- A statement explaining why you believe this regulation to be invalid.
Note.
Disclosure will not be considered adequate unless 1 and 2 above are provided using Form 8275-R. 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. If Form 8275-R 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.
