IRC section 6662 imposes accuracy related penalties for substantial understatement of tax liability or negligence or disregard of rules and regulations. Section 6694 imposes similar penalties on return preparers. Regulations section 1.6662-4(e) and (f) provide for reduction of these penalties if adequate disclosure of the tax treatment is made on Form 8275 or, if the position is contrary to a regulation on Form 8275-R.
The latest form for Disclosure Statement and Regulation Disclosure Statement expires 2023-01-31 and can be found here.
Federal Enterprise Architecture: General Government - Taxation Management
Form 8275 | Disclosure Statement | www.irs.gov/form8275 | Form |
Review document collections for all forms, instructions, and supporting documents - including paper/printable forms.