IRS EXTENDS REVENUE PROCEDURE ON ADEQUATE DISCLOSURE.

Rev. Proc. 93-33

SEC. 1. PURPOSE

This revenue procedure extends the application of Rev. Proc. 92-23, 1992-1 C.B. 737, to 1992 tax forms.

SEC. 2. BACKGROUND

Rev. Proc. 92-23 identifies circumstances under which the disclosure on a taxpayer's return of a position with respect to an item is adequate for the purpose of reducing the understatement of income tax under section 6662(d) of the Internal Revenue Code (relating to the substantial understatement component of the accuracy-related penalty), and for the purpose of avoiding the preparer penalty under section 6694(a) (relating to understatements due to unrealistic positions). Rev. Proc. 92-23 does not apply with respect to any other penalty provision (including the negligence or disregard provisions of the section 6662 accuracy-related penalty).

SEC. 3. PROCEDURE

Rev. Proc. 92-23 is applicable to any taxpayer filing a return on 1992 tax forms for a taxable year beginning in 1992, and to any taxpayer filing on 1992 tax forms in 1993 for short taxable years beginning in 1993. Except for this extension, there are no substantive or editorial changes to Rev. Proc. 92-23.

DRAFTING INFORMATION

The principal author of this revenue procedure is Marcia Rachy of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this revenue procedure, contact Ms. Rachy on (202) 622-4940 (not a toll-free call).