Rev. Proc. 2014-15 - Adequate disclosure on a return 

January 24:  Rev. Proc. 2014-15—which appears in the Internal Revenue Bulletin being released on Monday, January 27—updates earlier guidance (Rev. Proc. 2012-51) identifying circumstances under which disclosure on a taxpayer’s income tax return of an item or position is adequate for purposes of reducing the understatement of income tax for purposes of the accuracy-related penalty under section 6662(d).

The changes in Rev. Proc. 2014-15 are “editorial.” No substantive changes have been made. Rev. Proc. 2014-15 appears in Internal Revenue Bulletin 2014-5 [PDF 122 KB], dated January 27, 2014.

Rev. Proc. 2014-15 applies to any income tax return filed on 2013 tax forms for a tax year beginning in 2013, and to any income tax return filed in 2014 on 2013 tax forms for short tax years beginning in 2014.


Rev. Proc. 2012-51 updated still earlier guidance―Rev. Proc. 2012-15―which was issued in January 2012 to update the annual revenue procedure concerning circumstances when disclosure on a taxpayer's return with respect to an item or a position is adequate for purposes of:

  • Reducing the understatement of income tax under section 6662(d) (relating to the substantial understatement aspect of the accuracy-related penalty)
  • Avoiding the preparer penalty under section 6694(a) (relating to understatements due to unreasonable positions) with respect to income tax returns

Read TaxNewsFlash-United States (November 26, 2012) [PDF 67 KB]

©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International.

KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.

The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

Direct comments, including requests for subscriptions, to
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

Share this

Share this


Current and future KPMG clients may subscribe to TaxNewsFlash email alerts.

Email your contact information.

Other TaxNewsFlash publications

TaxNewsFlash-United States by year