SECTION 1. PURPOSE

This revenue procedure provides alternative disclosure procedures that are deemed to satisfy a taxpayer’s disclosure obligations under § 1.6011–4 of the Income Tax Regulations for transactions with a significant book-tax difference under § 1.6011–4(b)(6). Taxpayers also may continue to follow the disclosure procedures provided in § 1.6011–4 for disclosing transactions described in § 1.6011–4(b)(6).