Definitions and Special Rules

ID:
Office:
UILC:
CCA_2008093009440664
---
6664.00-00
Number: 200906049
Release Date: 2/6/2009
From: ---
Sent: Tuesday, September 30, 2008 9:44:11 AM
To: ---
Cc:
Subject: RE: Penalty Question
The qualified amended return regs were amended to add several new events, the date after which taxpayers may not file a qualified amended return. Among these are rules in Treas. Reg. section 1.6664-2(c)(3)(ii) for situations where the original return claims the benefit of an undisclosed listed transactions.
The effective date for this provision is complicated and is stated in section 1.6664-1(b)(3). I think the taxpayer is correct, however, that RP 94-69 (promulgated under the authority of 1.6664-2c)(4)(ii) or its predecessor) creates an exception to the application of the QAR rules to CIC taxpayers. --------- So, as long as the taxpayer complied with the terms of RP 94-69, I think its return is a QAR.