Friday, January 25, 2008
The IRS today released an advance copy of Rev. Proc. 2008-14, 2008-7 I.R.B. ___ (2/19/08), which defines what constitutes adequate disclosure on a tax return to avoid the § 6662(d) substantial understatement of income penalty and the § 6694(a) preparer penalty appplicable to unreasonable positions.