26 CFR §1.707-8

1. (a)In general. The disclosure referred to in § 1.707-3(c)(2) (regarding certain transfers made within two years of each other), § 1.707-5(a)(7)(ii) (regarding a liability incurred within two years prior to a transfer of property), and § 1.707-6(c) (relating to transfers of property from a partnership to a partner in situations analogous to those listed above) is to be made in accordance with paragraph (b) of this section.
2. (b)Method of providing disclosure. Disclosure is to be made on a completed Form 8275 or on a statement attached to the return of the transferor of property for the taxable year of the transfer that includes the following:
   1. (1)A caption identifying the statement as disclosure under section 707;
   2. (2)An identification of the item (or group of items) with respect to which disclosure is made;
   3. (3)The amount of each item; and
   4. (4)The facts affecting the potential tax treatment of the item (or items) under section 707.
3. (c)Disclosure by certain partnerships. If more than one partner transfers property to a partnership pursuant to a plan, the disclosure required by this section may be made by the partnership on behalf of all the transferors rather than by each transferor separately.