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.

Background

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]




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