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1. 88 FR 75744 — Federal Independent Dispute Resolution Operations
   IRCProposed Rules (FR)Proposed Nov 3, 2023
   ation 133.  Proposed 26 CFR 54.9816-8(b)(2)(ii)(A)( 5), 29 CFR 2590.716-8(b)(2)(ii)(A)( 5), and 45 CFR 149.510(b)(2)(ii)(A)( 5). Back to Citation 134.  Currently, the administrative fee is paid to the selected certified IDR entity and then remitted to the Departments. 26 CFR 54.9816-8T(d)(2)(i) and (e)(2)(ix), 29 CFR 2…
2. U.S. Tax Court — Michael Leon & Karin Policky Tilley v. Commissioner
   IRCCourt RulingsJul 21, 2008
   …ite being required to d o so . Accordingly, we hold that respondent satisfied his burden . Section :6664 provides an exception to the imposition of an accuracy-related penalty if the taxpayer establishes that there .was reasonable cause for the understatement and that the taxpayer acted in good faith with respect to th…
3. 86 FR 708 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm…
   IRCFinal Rules (FR)Jan 6, 2021
   2 (FDIC) (“synthetic exposure”). Back to Citation 32.   See 12 CFR 3.2 (OCC); 12 CFR 217.2 (Board); 12 CFR 324.2 (FDIC) (“investment in the capital of an unconsolidated financial institution” and “indirect exposure”). Back to Citation 33.   See 12 CFR 44.4 (OCC); 12 CFR 248.4 (Board); 12 CFR 351.4 (FDIC). Back to Citat…
4. T.C. Summary Opinion 2008-1 — Shawn Timothy Hynes v. Commissioner
   IRCCourt RulingsJan 2, 2008
   that he acted in good faith with respect to that portion . Sec . 6664(c)(1) ; sec . 1 .6664-4(b), Income Tax Regs . Although not defined in the Code, "reasonable cause" is viewed in the regulations as the exercise of ordinary business care and prudence . See sec . 301 .66511(c)(1), Proced . & Admin . Regs . Whether a …
5. 90 FR 23303 — Request for Information Regarding the Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule
   IRCProposed Rules (FR)Proposed Jun 2, 2025
   .210(a)(2)(xi). Back to Citation 20.  26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D). 21.  The TiC final rules also clarify that nothing in 26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D) requires th…
6. 29 C.F.R. § 2520.101-4 — [Reserved]
   ERISARegulationsJan 1, 2017related by meaning
   [Reserved]
7. 29 C.F.R. § 2520.102-1 — [Reserved]
   ERISARegulationsJan 1, 2017related by meaning
   [Reserved]
8. T.C. Memo. 2013-126 — Laura Ung v. Commissioner
   IRCCourt RulingsMay 13, 2013
   … both 10% of the tax required to be shown on the tax return and $5,000, see secs. 6211, 6662(d)(2), 6664(a). It is petitioner's burden to establish that the imposition of the penalty is not appropriate because, inter alia, of a defense such as reasonable cause under section 6664(c). See Higbee v. Commissioner, 116 T.C.…
9. 29 C.F.R. § 2520.104-28 — [Reserved]
   ERISARegulationsJan 1, 2017related by meaning
   [Reserved]
10. 29 C.F.R. § 2520.104-45 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
11. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002
    s. 6662(d)(2) (B)(ii), 6664(c)(1); secs. 1.6662-3(c), 1.6664-4(a), Income Tax Regs. - 15 - We consider the facts and circumstances in deciding whether the taxpayer acted with reasonable cause and in good faith. Sec. 6664(c)(1); sec. 1.6664-4(b)(1), Income Tax Regs. We conclude that petitioner acted in good faith and wa…
12. 29 C.F.R. § 2520.104a-7 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
13. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …us shifts to petitioners to prove that the penalties do not apply for 2004. See id. at 447. Section 6664(c)(1) provides that the accuracy-related penalty shall not be imposed with respect to any portion of an underpayment "if it is shown that there was a reasonable cause for such portion and that the taxpayer acted in …
14. 29 C.F.R. § 4281.14-4281.15 — [Reserved]
    PBGCRegulationsJul 1, 2019related by meaning
    [Reserved]
15. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …f competent professional advisers on whom they relied heavily and in good faith. Generally, section 6664(c) (1) provides an exception to the section 6662(a) accuracy-related penalty with respect to any portion of an underpayment if the taxpayer shows that there was reasonable cause for such portion and7that the taxpaye…
16. 29 C.F.R. § 4907.161-4907.169 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
17. 88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCProposed Rules (FR)Proposed Aug 3, 2023
    15-2715A1(a)(2)(xx), 29 CFR 2590.715-2715A1(a)(2)(xix), 45 CFR 147.210(a)(2)(xx). Back to Citation 170.  29 CFR 2520.102-2(a). Back to Citation 171.   See 26 CFR 54.9815-2715(a)(4)(ii)(B), 29 CFR 2590.715-2715(a)(4)(ii)(B), 45 CFR 147.200(a)(4)(ii)(B). Back to Citation 172.  26 CFR 54.9815-2719, 29 CFR 2590.715-2719, a…
18. 29 C.F.R. § 4000.28 — [Reserved]
    PBGCRegulationsDec 7, 2023related by meaning
    [Reserved]
19. 29 C.F.R. § 2530.205 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
20. 29 C.F.R. § 4907.171-4907.999 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]