Definition of Underpayment

ID:
Office:
UILC:
CCA_2011070809054664
---
6664.01-00
Number: 201138034
Release Date: 9/23/2011
From: ---
Sent: Friday, July 08, 2011 9:05:47 AM
To: ---
Cc:
Subject: FW: Follow up re Rev. Proc.
I would not call the submissions under Rev. Proc. 94-69 disclosure statements. The submissions are a form of a qualified amended return (QAR). QARs can either report tax or make disclosures without reporting additional tax. When you call a submission under RP 94-69 a disclosure statement it sounds like you are describing only the latter type of submission. ------------------------------------------------------------------------------2 ------------------------------------------Let me know if you have any questions.