Hi, George.  If you're still out there, do you have a citation for the statement that UPE should be added to basis (and if so, I assume it would be added to "Increases for the tax year" on Form 6198 Part II Line 7, yes?)?.  It makes sense.  It would be great if it's true.  But if I'm going to report that on an original or amended 1040, I would like to be able to cite the reg or other authoritative source.  Please let me know.  Thanks!