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Oil Partnership Loss - Disclosure requirement

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    Oil Partnership Loss - Disclosure requirement

    I was heard that it would be a misreporting if the oil partnership losses are reported without disclosure. I would like to know the reason why or in which cases disclosure statement should be filed for Oil Partnership Loss.
    I don’t understand why that loss is considered as substantial understatement of income tax (Form 8275) or Reportable Transaction (Form 8886)
    If required, what kind of languages for oil partnership loss are suggested to use on disclosure statement? Thanks.
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