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81. 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.
82. T.C. Summary Opinion 2017-64 — Wilfred Omoloh v. Commissioner
    IRCCourt RulingsAug 16, 2017
    …erstatement of income tax, which equals the deficiency, exceeds $5,000, see secs. 6211, 6662(d)(2), 6664(a). The accuracy-related penalty does not apply to any part of an underpayment of tax if it is shown the taxpayer acted with reasonable cause and in good faith with respect to that portion. Sec. 6664(c)(1). The dete…
83. 29 C.F.R. § 2570.30(a) — Scope of this subpart.
    ERISARegulationsApr 8, 2024related by meaning
    (a) (a) The rules of procedure set forth in this subpart apply to applications for prohibited transaction exemptions issued by the Department under the authority of: (a)(1) (1) Section 408(a) of the Employee Retirement Income Security Act of 1974 (ERISA); (a)(2) (2) Section 4975(c)(2) of the Internal Revenue Code of 19…
84. T.C. Summary Opinion 2013-11 — Steven L. Jarvis, and Estate of Cynthia S. Jarvis, Deceased, Steven L. Jarvis, Special Administrator v. Commissioner
    IRCCourt RulingsFeb 19, 2013
    …cted in good faith regarding part of the underpayment, no penalty is imposed on that part. See sec. 6664(c)(1); sec. - 9 - 1.6664-4(a), Income Tax Regs. An important factor for demonstrating reasonable cause and good faith is the extent of the taxpayer's effort to determine the proper tax liability. Sec. 1.6664-4(b)(1)…
85. 29 C.F.R. § 2530.200b-5 — Seasonal industries. [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    Seasonal industries. [Reserved]
86. T.C. Summary Opinion 2012-103 — Gary Wayne Doolittle v. Commissioner
    IRCCourt RulingsOct 25, 2012
    …to be shown on the return or $5,000. Sec. 6662(d)(1)(A); sec. 1.6662-4(b), Income Tax Regs. Section 6664(c)(1) provides that the penalty under section 6662(a) shall not apply to any portion of an underpayment if it is shown that there was reasonable cause for the taxpayer's position and that the taxpayer acted in good …
87. 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.
88. T.C. Memo. 2012-37 — Ifeanyi David & Ann Ada Onyekwena v. Commissioner
    IRCCourt RulingsApr 26, 2012
    …gence. - 14 - because of reasonable cause, substantial authority, or the like. Secs. 6662(d)(2)(B), 6664(c); Higbee v. Commissioner, 116 T.C. at 449. Respondent has met his burden of production for an accuracy-related penalty based on a substantial understatement of income tax because petitioners' understatement of inc…
89. 29 C.F.R. § 2570.113 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
90. T.C. Summary Opinion 2009-156 — Dean Gochis v. Commissioner
    IRCCourt RulingsOct 13, 2009
    …harr advised him that the partnership income paid to his sons would not be taxable to him . Section 6664(c)(1) providesia defense to the section 6662 penalty for any portion of an underpayment where . reasonable cause existed and the taxpayer acted in good faith . In determining whether a taxpayer reasonably relied in …
91. Treas. Reg. § 1.410(b)-1 — [Reserved]
    IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
92. T.C. Memo. 2015-244 — Jeremiah J. O'Connor & Mary K. O'Connor v. Commissioner
    IRCCourt RulingsDec 16, 2015
    ng the income for 2003 equal to the value of the O'Connor policy for that year. Section 6664(c)(1) provides that the penalty shall not be imposed with respect to any portion of an underpayment if a taxpayer shows that there was reasonable cause for, and that the taxpayer acted in good faith with respect to, that portio…
93. 29 C.F.R. § 2520.104b-10(b) — Summary Annual Report.
    ERISARegulationsApr 25, 2023related by meaning
    (b) (b) [Reserved]
94. T.C. Memo. 2012-329 — Thomas S. Gluckman & Roby R. Gluckman v. Commissioner
    IRCCourt RulingsNov 28, 2012
    or she acted with reásonable cause and in good faith. See sec. 6664(c)(1); Higbee v. Commission r, .116 T.C. at 447, 448. The decision as to whether a taxpayer acted with re sonable cause and in good faith is made on a case-by-case basis, taking into account all of the pertinent facts and circumstances. See sec. 1.6664…
95. 76 FR 76235 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements
    ERISAProposed Rules (FR)Proposed Dec 6, 2011related by meaning
    ia for determining if it appears that the MEWA or any person acting as an agent or employee of the MEWA has engaged in these forms of alleged conduct. Proposed paragraph (b)(2) of section 2560.521-1 addresses the statutory standard of fraudulent conduct. Under the proposed rules, fraudulent conduct is an act or omissio…
96. 29 C.F.R. § 2570.93 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(5) civil penalty proceedings, this section shall apply in lieu of 29 CFR 18.10.
97. T.C. Memo. 2010-262 — Hal Hollingsworth v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …nderpayment and -(2) that the taxpa~yer acted in good faith with respect to the underpayment. Sec. -6664-(c) (1) Regulations promulgated under section 6664(c) further provide that -the determination of reasonable cause and good faith "is made o a case-by-case basis, taking into account all pertinent facts and circumsta…
98. 29 C.F.R. § 4262.17(g) — Other provisions.
    PBGCRegulationsAug 8, 2022related by meaning
    (g) (g) If any provision in this part is held to be invalid or unenforceable by its terms, or as applied to any person or circumstance, or stayed pending further agency action, the provision will be construed so as to continue to give the maximum effect to the provision permitted by law, unless such holding will be one…
99. T.C. Memo. 2010-39 — Thomas & Carol Rosato v. Commissioner
    IRCCourt RulingsFeb 25, 2010
    de~ i by taking int o account all of the pertinent facts and circumstances . Sec . . 1 .6664-4(b)(1), Income Tax Regs . IThe most important factor i s the extent of the taxpayer's effort to assess his or her proper tax liability . Id . This factor includes, in some circumstances, the taxpayer's reasonable and good fait…
100. 29 C.F.R. § 2570.153 — Parties.
     ERISARegulationsJan 1, 2017related by meaning
     For section 3(40) Finding Proceedings, this section shall apply instead of 29 CFR 18.10.