On September 8, 2010, the IRS released proposed regulations 1.6012-2(a)(4)-(5) which require certain business taxpayers to attach the Schedule UTP, Uncertain Tax Position Statement, to their income tax returns effective for tax years beginning after December 15, 2009 and ending after the date of publication of the final regulations. The proposed regulations were published in the Federal Register on September 9.
Please see full publication below for more information.