WebSection 6664 (c) provides a reasonable cause and good faith exception to the accuracy-related penalty. Rules relating to the reasonable cause and good faith exception are set forth in § 1.6664-4. ( b) Effective date - ( 1) In general. WebSection 6662 (a) imposes an accuracy-related penalty on any portion of an underpayment of tax (as defined in section 6664 (a) and § 1.6664-2) required to be shown on a return if such portion is attributable to one or more of the following types of misconduct: ( 1) Negligence or disregard of rules or regulations (see § 1.6662-3 );

OFFICE OF TAX APPEALS STATE OF CALIFORNIA A.

WebI.R.C. § 664 (b) (1) — First, as amounts of income (other than gains, and amounts treated as gains, from the sale or other disposition of capital assets) includible in gross income to … simon strawhorn

M. MUDGE OPINION

WebThis penalty will not apply, however, if the overvaluation does not result in a substantial misstatement of taxes—that is, exceeding $5,000 (IRC section 6662(e)(1))—or the taxpayer can show reasonable cause and that it acted in good faith (IRC section 6664(c)(1)). WebSec. 6662A. Imposition Of Accuracy-Related Penalty On Understatements With Respect To Reportable Transactions IRC Subtitle F Chapter 68 Subchapter A Part II § 6662a Sec. 6662A. Imposition Of Accuracy-Related Penalty On Understatements With Respect To Reportable Transactions I.R.C. § 6662A (a) Imposition Of Penalty — WebThe provisions of § 1.6662-4 (f) (2), which permit disclosure in accordance with an annual revenue procedure for purposes of the substantial understatement penalty, do not apply … simons town wedding venues