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Go to Treas. Reg. § 1.6664 (not yet in the library — opens the official source)
108 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013
    . 2002); sec. 1.6664-4(b)(1), Income Tax Regs. Generally, the most important factor is the extent of the taxpayer's effort to assess his or her - 13 - proper tax liability. Humphrey, Farrington & McClain, P.C. v. Commissioner, T.C. Memo. 2013-23; sec. 1.6664-4(b)(1), Income Tax Regs. Petitioners contend they had reason…
  2. 29 C.F.R. § 2570.115 — Consent order or settlement.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, the following shall apply in lieu of § 18.9 of this title.
  3. T.C. Summary Opinion 2017-51 — Arthur Dulik, Jr. & Ellen B. Kugler Dulik v. Commissioner
    IRCCourt RulingsJul 13, 2017
    d circumstances of a particular case. Sec. 1.6664-4(b)(1), Income Tax Regs. As previously discussed, petitioners kept adequate records to substantiate the legal fees. Further, respondent determined and we conclude that petitioners are entitled to deduct their legal fees as an itemized deduction (subject to applicable l…
  4. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014
    …ion, and we need not analyze whether petitioners had a reasonable basis for their position. Section 6664(c)(1) provides another method by which petitioners may avoid the section 6662(a) penalty: no penalty shall be imposed under section 6662 with regard to any portion of an underpayment if it can be shown that there wa…
  5. 29 C.F.R. § 2570.135 — Consent order or settlement.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, the following shall apply in lieu of § 18.9 of this title.
  6. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    mission of additional information from the disputing parties at 26 CFR 54.9816-8(c)(2)(ii), 29 CFR 2590.716-8(c)(2)(ii), and 45 CFR 149.510(c)(2)(ii). To clarify and establish a standard process for disputes to be withdrawn from the Federal IDR process, the Departments are finalizing four conditions in which a dispute …
  7. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013
    …ion 6662(a) if the taxpayer establishes that he acted with reasonable cause and in good faith. Sec. 6664(c)(1). Circumstances that indicate reasonable cause and good faith include reliance on the advice of a tax professional or an honest misunderstanding of the law that is reasonable in light of all the facts and circu…
  8. IRCRegulationsAug 3, 2026related by meaning
    (b) (b) For further guidance, see 29 CFR 2590.716-3.
  9. T.C. Memo. 2013-152 — William K. McGraw v. Commissioner
    IRCCourt RulingsJun 17, 2013
    …production by demonstrating a "substantial understatement of income tax." See sec. 7491(c). 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 …
  10. 29 C.F.R. § 2570.2 — Definitions.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title:
  11. T.C. Memo. 2011-83 — Bruce A. & Carol Anfinson Brown v. Commissioner
    IRCCourt RulingsApr 12, 2011
    …cted in good faith regarding part of the underpayment, no penalty is imposed on that part. See sec. 6664(c) (1); sec. 1.6664-4(a), Income Tax Regs. The Browns argue that they did not report the item because they believed that Northwestern based the Form 1099-R on the theory that a debtor has a taxable gain when a credi…
  12. 20 C.F.R. § 901.1 — Definitions.
    Joint BoardRegulationsOct 18, 2016related by meaning
    As used in this part, the term:
  13. T.C. Memo. 2008-93 — Blake Sime & Susan M. Atkin v. Commissioner
    IRCCourt RulingsApr 10, 2008
    …hat they acted with reasonable cause and in good faith with respect to the underpayment . See sec . 6664(c)(1) ; see also Higbee v . Commissioner , supra at 447 ; sec . 1 .6664-4(b)(1), Income Tax Regs . Respondent satisfied the burden of production . Petitioners' 2002 income tax return contains an understatement of ta…
  14. ERISARegulationsJul 27, 2020related by meaning
    (b) (b) Fulfilling the disclosure obligation.
  15. 29 C.F.R. § 2570.4 — Parties.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  16. T.C. Summary Opinion 2005-114 — Francis N. & Patricia A. Leonard v. Commissioner
    IRCCourt RulingsAug 4, 2005
    …ofessional tax adviser does not necessarily demonstrate reasonable cause and good faith. See sec. 1.6664-4(b)(1), Income Tax Regs. All facts and circumstances must be taken into account. Sec. 1.6664-4(c)(1), Income Tax Regs. The advice must be based upon all pertinent facts and the applicable law. Sec. 1.6664-4(c)(1)(i…
  17. 29 C.F.R. § 2570.133 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  18. T.C. Memo. 2001-118 — Roydell Campbell v. Commissioner
    IRCCourt RulingsMay 17, 2001
    …payment, and (2) the taxpayer acted in good faith with - 8 - respect to such underpayment. See sec. 6664(c). Whether the taxpayer acted with reasonable cause and in good faith is determined by the relevant facts and circumstances. The most important factor is the extent of the taxpayer’s effort to assess the proper tax…
  19. 29 C.F.R. § 2570.63 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(2) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  20. 157 T.C. No. 10 — Andrew McNulty & Donna McNulty v. Commissioner
    IRCCourt RulingsNov 18, 2021
    with respect to that portion. Sec. 6664(c)(1). A determ ination of - 22 - reasonable cause and good faith is m ade on a case-by-case basis taking into account all pertinent facts and circum stances, with the m ost im portant factor being the taxpayers’ efforts to assess their proper liability. Sec. 1.6664-4(b), Incom e…