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81. Treas. Reg. § 54.9816-8(h)(1) — Independent dispute resolution process.
    IRCRegulationsAug 28, 2026related by meaning
    (h)(1) (1) Any provision of this section held to be invalid or unenforceable by its terms, or as applied to any person or circumstance, will be construed so as to continue to give maximum effect to the provision permitted by law, unless such holding is one of utter invalidity or unenforceability, in which event the pro…
82. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007related by meaning
    ddition to tax must be sustained. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or groundless or the taxpayer has instituted or pursued the proceeding primarily for delay. Respondent has n…
83. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    alty equal to 20 percent of the portion of the underpayment of income tax that is attributable to negligence. Negligence includes the failure to - 7 - make a reasonable attempt to comply with the law and disregard of the rules and regulations includes any "careless, reckless, or intentional disregard." Sec. 6662(c). Wh…