nondisclosed noneconomic substance transaction

(2) Nondisclosed noneconomic substance transactions For purposes of this subsection, the term “nondisclosed noneconomic substance transaction” means any portion of a transaction described in subsection (b)(6) with respect to which the relevant facts affecting the tax treatment are not adequately disclosed in the return nor in a statement attached to the return.


26 USC § 6662(i)(2)

Scoping language

For purposes of this subsection
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