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Treas. Reg. § 1.6662-7

Omnibus Budget Reconciliation Act of 1993 changes to the accuracy-related penalty.
eCFR amendment effective 2016-12-30 · current · last amended by T.D. 8790, 63 FR 66435, Dec. 2, 1998
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(a) Scope. The Omnibus Budget Reconciliation Act of 1993 made certain changes to the accuracy-related penalty in section 6662. This section provides rules reflecting those changes.
(b) No disclosure exception for negligence penalty. The penalty for negligence in section 6662(b)(1) may not be avoided by disclosure of a return position.
(c) Disclosure standard for other penalties is reasonable basis. The penalties for disregarding rules or regulations in section 6662(b)(1) and for a substantial understatement of income tax in section 6662(b)(2) may be avoided by adequate disclosure of a return position only if the position has at least a reasonable basis. See § 1.6662-3(c) and §§ 1.6662-4(e) and (f) for other applicable disclosure rules.
(d) Reasonable basis. For purposes of §§ 1.6662-3(c) and 1.6662-4(e) and (f) (relating to methods of making adequate disclosure), the provisions of § 1.6662-3(b)(3) apply in determining whether a return position has a reasonable basis.
Source credit, amendments & notes

[T.D. 8617, 60 FR 45665, Sept. 1, 1995, as amended by T.D. 8790, 63 FR 66435, Dec. 2, 1998]

Treas. Reg. § 1.6662-7 — Omnibus Budget Reconciliation Act of 1993 changes to the accuracy-related penalty. · eCFR amendment effective 2016-12-30 · https://pensionresource.website/EAMain?content=EAMain.Law&id=cfr26-1.6662-7&asof=2008-05-22 · printed Oct 25, 2026
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  • (a) Scope.
  • (b) No disclosure exception for negligence penalty.
  • (c) Disclosure standard for other penalties is reasonable basis.
  • (d) Reasonable basis.
Implements
I.R.C. § 6662 Imposition of accuracy-related penalty on underpayments

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Dec 30, 2016currenteCFR amendment effective 2016-12-30T.D. 8790, 63 FR 66435, Dec. 2, 1998View
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