If you are uncertain whether a transaction is a reportable transaction under Regulations section 1.6011-4, you may indicate
that you are filing on
a protective basis by writing “Protective Disclosure” at the top of the form.
Enter the name, if any, by which the transaction is known or commonly referred to. If no name exists, provide a short identifying
description of
this transaction that distinguishes it from other reportable transactions in which you have participated (or may participate
in the future). If you
are reporting more than one transaction and the transactions have different names, write “See Attached” and attach a list.
If the transaction has been registered as a tax shelter under section 6111, provide the registration number that has been
assigned to the tax
shelter. If you are reporting more than one transaction and tax shelter registration number, write “See Attached” and attach a list. Generally, a
tax shelter registration number is reported on Form 8271, Investor Reporting of Tax Shelter Registration Number. If you are a partner of a
partnership or a shareholder of an S corporation that invested in a tax shelter, you may receive a Form 8271 with your Schedule
K-1.
Check the box for each category that applies to the transaction being reported. The six reportable transaction categories
are described under
Participation in a Reportable Transaction on page 1.
Provide a brief identifying description of the listed transaction and identify the notice, revenue ruling, or regulation (e.g.,
Regulations section
1.634(a)-8 or Notice 2002-70) that identified the listed transaction as shown in Notice 2001-51 or later IRS guidance.
Do not report more than one transaction on this form unless the transactions are the same or substantially similar. See the
definition of
substantially similar onpage 1.
Include the facts that may be relevant to understanding the claimed or expected Federal income tax treatment of the transaction.
In addition:
- If you checked box 2b, explain how your disclosure of information concerning the transaction was limited (e.g., by contract or
verbal agreement) and the nature and extent of the disclosure limitations. See Regulations section 1.6011-4(b)(3) for more
details.
- If you checked box 2c, describe the terms of the contractual protection. See Regulations section 1.6011-4(b)(4) for more
details.
- If you checked box 2d, explain how you calculated the basis of the asset for which there was a loss.
If you need more space, attach separate sheets.
Tax benefits include deductions, exclusions from gross income, nonrecognition of gain, tax credits, adjustments (or the absence
of adjustments) to
the basis of property, status as a tax-exempt organization, or any other tax consequences that may affect the amount, timing,
character, or source of
any item of income, gain, loss, expense, or credit.
If you need more space, attach separate sheets.
