Treasury Regulations (26 C.F.R.)
26 CFR § 1.6664-0
Table of contents.
This section lists the captions in §§ 1.6664-1 through 1.6664-4T.
(a) In general.
(b) Effective date.
(1) In general.
(2) Reasonable cause and good faith exception to section 6662 penalties.
(i) For returns due after September 1, 1995.
(ii) For returns filed after December 31, 2002.
(3) Qualified amended returns.
(a) Underpayment defined.
(b) Amount of income tax imposed.
(c) Amount shown as the tax by the taxpayer on his return.
(1) Defined.
(2) Effect of qualified amended return.
(3) Qualified amended return defined.
(i) General rule.
(ii) Undisclosed listed transactions.
(4) Special rules.
(5) Examples.
(d) Amounts not so shown previously assessed (or collected without assessment).
(e) Rebates.
(f) Underpayments for certain carryback years not reduced by amount of carrybacks.
(g) Examples.
(a) In general.
(b) Order in which adjustments are taken into account.
(c) Manner in which unclaimed prepayment credits are allocated.
(d) Examples.
(a) In general.
(b) Facts and circumstances taken into account.
(1) In general.
(2) Examples.
(c) Reliance on opinion or advice.
(1) Fact and circumstances; minimum requirements.
(i) All facts and circumstances considered.
(ii) No unreasonable assumptions.
(iii) Reliance on the invalidity of a regulation.
(2) Advice defined.
(3) Cross-reference.
(d) Underpayments attributable to reportable transactions.
(e) Pass-through items.
(f) Special rules for substantial understatement penalty attributable to tax shelter items of corporations.
(1) In general; facts and circumstances.
(2) Reasonable cause based on legal justification.
(i) Minimum requirements.
(A) Authority requirement.
(B) Belief requirement.
(ii) Legal justification defined.
(3) Minimum requirements not dispositive.
(4) Other factors.
(g) Transactions between persons described in section 482 and net section 482 transfer price adjustments. [Reserved]
(h) Valuation misstatements of charitable deduction property.
(1) In general.
(2) Definitions.
(i) Charitable deduction property.
(ii) Qualified appraisal.
(iii) Qualified appraiser.
(3) Special rules.
(a)-(c) [Reserved]
(d) Transactions between persons described in section 482 and net section 482 transfer price adjustments.
[T.D. 8381, 56 FR 67505, Dec. 31, 1991, as amended by T.D. 8519, 59 FR 4799, Feb. 2, 1994; T.D. 8617, 60 FR 45666, Sept. 1, 1995; T.D. 8656, 61 FR 4885, Feb. 9, 1996; T.D. 8790, 63 FR 66435, Dec. 2, 1998; T.D. 9109, 68 FR 75128, Dec. 30, 2003; T.D. 9309, 72 FR 903, Jan. 9, 2007]
Source: view the official text
In this part (40 sections)
- 1.6655-0 · Table of contents.
- 1.6655-1 · Addition to the tax in the case of a corporation.
- 1.6655-2 · Annualized income installment method.
- 1.6655-2T · Safe harbor for certain installments of tax due before July…
- 1.6655-3 · Adjusted seasonal installment method.
- 1.6655-4 · Large corporations.
- 1.6655-5 · Short taxable year.
- 1.6655-6 · Methods of accounting.
- 1.6655-7 · Addition to tax on account of excessive adjustment under…
- 1.6655(e)-1 · (e)-1 Time and manner for making election under the…
- 1.6662-0 · Table of contents.
- 1.6662-1 · Overview of the accuracy-related penalty.
- 1.6662-2 · Accuracy-related penalty.
- 1.6662-3 · Negligence or disregard of rules or regulations.
- 1.6662-4 · Substantial understatement of income tax.
- 1.6662-5 · Substantial and gross valuation misstatements under chapter…
- 1.6662-5T · Substantial and gross valuation misstatements under chapter…
- 1.6662-6 · Transactions between persons described in section 482 and…
- 1.6662-7 · Omnibus Budget Reconciliation Act of 1993 changes to the…
- 1.6662-9 · Inconsistent estate basis reporting.
- 1.6664-0 · Table of contents.
- 1.6664-1 · Accuracy-related and fraud penalties; definitions, effective…
- 1.6664-2 · Underpayment.
- 1.6664-3 · Ordering rules for determining the total amount of penalties…
- 1.6664-4 · Reasonable cause and good faith exception to section 6662…
- 1.6664-4T · Reasonable cause and good faith exception to section 6662…
- 1.6694-0 · Table of contents.
- 1.6694-1 · Section 6694 penalties applicable to tax return preparers.
- 1.6694-2 · Penalty for understatement due to an unreasonable position.
- 1.6694-3 · Penalty for understatement due to willful, reckless, or…
- 1.6694-4 · Extension of period of collection when tax return preparer…
- 1.6695-1 · Other assessable penalties with respect to the preparation…
- 1.6695-2 · Tax return preparer due diligence requirements for certain…
- 1.6696-1 · Claims for credit or refund by tax return preparers or…
- 1.6709-1T · Penalties with respect to mortgage credit certificates…
- 1.6851-1 · Termination assessments of income tax.
- 1.6851-2 · Certificates of compliance with income tax laws by departing…
- 1.6851-3 · Furnishing of bond to insure payment; cross reference.
- 1.7476-1 · Interested parties.
- 1.7476-2 · Notice to interested parties.