167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026★ strong match
…meaning of terms such as “negligence,”
“substantial valuation misstatement,” and so on).
11
Section 6664(c) is titled “ Reasonable cause exception for underpayments .”
52
tax. Relevant portions of section 6662(e) and (h) also refer to
“underpayment[s].” § 6662(e)(2) , (h)(1). Even portions of section 6664
that are broa…
IRCCode / StatuteJan 5, 2023related by meaning
(i) (i) Increase in penalty in case of nondisclosed noneconomic substance transactions
(i)(1) (1) In general In the case of any portion of an underpayment which is attributable to one or more nondisclosed noneconomic substance transactions, subsection (a) shall be applied with respect to such portion by substituting "4…
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
… and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
IRCCourt RulingsFeb 25, 2016★ strong match
…eased from 20% to 30% of the
amount of the understatement if the disclosure requirements of section
6664(d)(2)(A), requiring disclosure in accordance with the regulations under
section 6011, are not met. Sec. 6662A(c). Section 6664(d) provides a defense to
section 6662A if the taxpayer acted with reasonable cause and i…
IRCCode / StatuteJan 24, 2020related by meaning
(c)(2)(C) (C) Split-interest trusts In the case of a trust which is required to file a return under section 6034(a), subparagraphs (A) and (B) of this paragraph shall not apply and paragraph (1) shall apply in the same manner as if such return were required under section 6033, except that— In addition to any penalty im…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…
See
Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021).
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/05/03/provider-charges-relative-to-medicare-rates-2012-2018/.
Back to Citation
210…
IRCCourt RulingsJun 14, 2012related by meaning
ess doctrine, courts may invalidate laws if "'men of common
intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor
- - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945
F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra
addresses tran…
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…
IRCCourt RulingsMay 13, 2013★ strong match
… 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.…
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 …
IRCCourt RulingsMay 19, 2011★ strong match
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
IRCCourt RulingsAug 27, 2018related by meaning
arguments to justify them. We therefore hold that petitioner
- 10 -
[*10] is liable for the penalty for an underpayment attributable to a substantial understatement of income tax under section 6662(a) and (b)(2) for each year.
V. Section 6673 Sanction
Respondent moved that the Court impose sanctions against petitioner…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
se and Good Faith
Section 6664(c)(1) provides that no accuracy-related penalty
appl ies to any portion of an underpayment for which the taxpayer shows reasonable cause and good faith. See Higbee , 116 T.C. at 448.
Reasonable cause is determined case by case, considering all pertinent
facts and circumstances. Treas. Reg…
IRCCourt RulingsAug 1, 2005★ strong match
his annuity policies. As
stated earlier, section 72(e)(5) applies to the surrender of an
annuity contract. See sec. 72(e)(5)(E). Absent exceptions not applicable in the instant case, the law is well settled that a
distribution upon the complete surrender of an annuity contract
is includable in gross income to the exten…
IRCCourt RulingsJan 14, 2013★ strong match
elated
penalty for the 2002, 2003, 2004, and 2005 tax years.
- 39 -
[*39] Subsection (a) of section 6662 imposes an accuracy-related penalty of 20% of any underpayment that is attributa le to causes specified in subsection (b).
Respondent asserts that one or botli of two causes justify the imposition of the
penalty for…
IRCCourt RulingsMar 9, 2011related by meaning
ds of thousands of dollars
in DISC commissions each year from a well-established business,
and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount.
-28IV. Section 6662(a) Penalty
Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
IRCCourt RulingsMar 16, 2015related by meaning
… demonstrating a "substantial understatement of income tax." See secs. 6662(b)(2), 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 …
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
IRCCourt RulingsJan 2, 2020related by meaning
er. Mrs. Gebman did not provide any evidence that persuades us that
she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file
amendment to petition filed August 28, 2019.
VI. Section 6662(a) Penalties
Section 6662(a) an…
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…