March 29, 2006
California Listed Transactions - California listed transactions entered into prior to September 2, 2003, are not required to be disclosed under the provisions of California Revenue and Taxation Code section 18407 unless the transaction meets one of the other five categories of a reportable transaction as defined under Treasury Regulation 1.6011-4.
Listed Transactions - If an abusive tax transaction is listed after filing the tax return, including an amended return, a taxpayer is required to disclose that transaction no later than the filing of the next tax return due. A taxpayer can also amend the tax year in which the abusive tax transaction was claimed to disclose the transaction immediately upon the listing of the transaction. The first time a transaction is disclosed, the taxpayer is also required to mail a duplicate copy of the disclosure statement to Tax Shelter Filing, Franchise Tax Board, PO Box 1673, MS F-385, Sacramento CA 95812-1673.