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Go to Treas. Reg. § 1.6664-2 (not yet in the library — opens the official source)
83 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023★ strong match
    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. 89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern
    IRCFinal Rules (FR)May 6, 2024related by meaning
    esses, such as International Traffic in Arms Regulations (ITAR) registration or National Institute of Standards and Technologies (NIST) certification. The Treasury Department and the IRS appreciate the commenters' desire for certainty regarding the procedures for establishing reasonable reliance and due diligence. As d…
  3. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026★ strong match
    …VICES For the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR part 149 as set forth below: PART 149—SURPRISE BILLING AND TRANSPARENCY REQUIREMENTS 15. The authority citation for part 149 continues to read as follows: ( printed page 34070) Authority: 42 U.S.C. 300gg-92 and 300gg…
  4. 75 FR 44656 — Registration of Mortgage Loan Originators
    IRCFinal Rules (FR)Jul 28, 2010related by meaning
    h information on how to obtain an RSSD number for the purposes of this rulemaking. The Agencies received no other significant comments on § __.103(e). We also have amended proposed § __.103(e)(1) to require system administrators to follow NMLS protocols to verify their own identity and to attest that they have the auth…
  5. 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…
  6. 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…
  7. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026★ strong match
    …es “reasonable cause” and shows that he “acted in good faith with respect to [the underpayment].” § 6664(c)(1). Th e reasonable cause defense may be available where a taxpayer makes a “substantial” valuation overstatement with respect to charitable contribution property. See § 6664(c)(3). The reasonable cause defense i…
  8. 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 …
  9. Treas. Reg. § 54.4980H-6(a) — Administration and procedure.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) In general. [Reserved]
  10. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021related by meaning
    …oup health plans and health insurance issuers, and not with providers. HHS proposes to codify in 45 CFR 150.503(d) the statutory language, located at section 1128A(k) of the SSA and included via section 2799B-4 of the PHS Act, that allows HHS to bring an action to prevent a provider or facility from engaging in activit…
  11. 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…
  12. 88 FR 11388 — Extension of Import Restrictions on Archaeological and Ethnological Materials of Libya
    IRCFinal Rules (FR)Feb 23, 2023related by meaning
    …) of Executive Order 12866. Signing Authority This regulation is being issued in accordance with 19 CFR 0.1(a)(1), pertaining to the Secretary of the Treasury's authority (or that of his/her delegate) to approve regulations related to customs revenue functions. Troy A. Miller, the Acting Commissioner of CBP, having rev…
  13. IRCRegulationsAug 3, 2026related by meaning
    (b) (b) For further guidance, see 29 CFR 2590.716-3.
  14. 75 FR 51623 — Registration of Mortgage Loan Originators
    IRCFinal Rules (FR)Aug 23, 2010related by meaning
    and facilitates employee compliance. We did not receive substantive comments addressing this requirement and therefore adopt § __.104(b) as proposed. Third, proposed § __.104(c) required that policies and procedures must establish procedures to comply with the unique identifier requirements in § __.105. Once again, th…
  15. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026related by meaning
    Similarly, the proposed notice requirements at paragraphs (c)(3)(ix)(D) of 26 CFR 54.9831-1, and 29 CFR 2590.732 and paragraph (b)(3)(ix)(D) of 45 CFR 146.145 are separate requirements that can stand independently of the standards under paragraphs (c)(3)(ix)(A), (B), and (C) of 26 CFR 54.9831-1, and 29 CFR 2590.732 and…
  16. 81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCProposed Rules (FR)Proposed Jun 1, 2016★ strong match
    3(i) and 12 U.S.C. 5381(a)(3). Back to Citation 24.  12 CFR part 50 (OCC), 12 CFR part 249 (Board), and 12 CFR part 329 (FDIC). Back to Citation 25.   See 12 CFR 3.2 (OCC), 12 CFR 217.2 (Board), and 12 CFR 324.2 (FDIC). Back to Citation 26.   See section II.D and II.C of this Supplementary Information section for discu…
  17. 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.…
  18. IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
  19. IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
  20. 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…