Disclosure? Don't File an Uncertain Tax Return Without It - 2019 Tax Season Chaos (2 hours)

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Apr 1, 2020

Registration: 11:30 AM / Program: 12:00 PM - 2:00 PM


Member Fee: $0.00
Nonmember Fee: $0.00

Available Discounts

AICPA Member: None
Full time Accounting Educator: None


With the plethora of Tax Cuts Jobs Act (TCJA) unanswered questions coming at us like a pack of defensive linemen, this tax season is (or at least seems to be) out of control. Approaches by tax software companies are “all over the board” moving targets. Clients want their tax returns now. If IRS scrutinizes a return (years later), they’ll have the benefit of hindsight. Much of the law is messy, messy, messy, messy.

What is a tax preparer to do? One approach is to disclose uncertainties (re: §199A or any other messy area) to IRS on tax returns now. Yes, that’s right. Kiss and tell. Tell the adversary what you’re up to. All for the sake of seeing your client and you through to a better day.

Designed For

Tax preparers and planners desiring to avoid client accuracy and preparer penalties and malpractice exposure


  • To learn how to scout out tax positions needing disclosure, keep a good tax file, involve client in approach and disclose uncertain tax positions on federal tax returns

Major Subjects

  • How does claiming §199A put the whole tax return in peril?
  • How the accuracy and preparer penalties for TCJA is a “tough go” early on
  • When disclosure may help (and, when it may not)
  • If disclose, specifically how? Is Form 8275 necessary, or does white paper cut it?
  • But, doesn’t disclosure get you audited?
  • What does age-old Form 8082 (Notice of Inconsistent Position) have to do with all of this anyway?

This event has already passed. If you have any questions, please contact us at 503-641-7200 or email profdev@orcpa.org.