How does a preparer disclose a position in the case of items attributable to a pass-through entity?
Disclosure in the case of items attributable to a pass-through entity (pass-through items) is generally made with respect to the return of the entity. Thus, disclosure in the case of pass-through items must be made on the entity’s prepared tax return with a complete Form 8275 or 8275-R disclosure statement, or on the entity’s return in accordance with the annual revenue procedure, if applicable.
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