SECTION 1. PURPOSE

This revenue procedure updates Rev. Proc. 2023-40, 2023-51 I.R.B. 1553, and identifies circumstances under which the disclosure on a taxpayer’s income tax return with respect to an item or position is adequate for the purpose of reducing the understatement of income tax under section 6662(d) of the Internal Revenue Code (relating to the substantial under­ statement aspect of the accuracy-related penalty), and for the purpose of avoid­ ing the tax return preparer penalty under section 6694(a) (relating to understate­ ments due to unreasonable positions) with respect to income tax returns. This revenue procedure does not apply with respect to any other penalty provisions (including but not limited to the disre­ gard provisions of the section 6662(b) (1) accuracy-related penalty, the sec­ tion 6662(i) increased accuracy-related penalty in the case of nondisclosed non­ economic substance transactions, and the section 6662(b)(7) and (j) increased accuracy-related penalty in the case of undisclosed foreign financial asset understatements). If this revenue proce­ dure does not include an item or posi­ tion, disclosure is adequate with respect to that item or position only if made on a properly completed Form 8275 or 8275R, as appropriate, attached to the return for the year or to a qualified amended return. See Treas. Reg. § 1.6664-2(c) for information about qualified amended returns.

This revenue procedure applies to any income tax return filed on 2024 tax forms for a taxable year beginning in 2024, and to any income tax return filed in 2025 on 2024 tax forms for short taxable years beginning in 2025.