WebUnder IRC section 6662 (d), taxpayers are subject to a 20% accuracy-related penalty if the understatement exceeds the greater of 10% of the proper tax liability or $5,000 ($10,000 … WebThere may be substantial authority for the tax treatment of an item despite the absence of certain types of authority. Thus, a taxpayer may have substantial authority for a position that is supported only by a well-reasoned construction of the applicable statutory … If a return position is reasonably based on one or more of the authorities set forth in …
Income Tax I: Tax Research Flashcards Quizlet
WebJul 1, 2024 · Although it does not appear that the return position in question was contrary to a regulation, the reference to substantial authority as a safe harbor against the disregard-of-regulations penalty is notable because, based on the structure of Sec. 6662, substantial authority is only relevant to the substantial-understatement component of the … WebMay 23, 2016 · The types of authorities that may be considered is broad, and includes the Internal Revenue Code, Treasury Regulations (proposed, temporary and final), other IRS published guidance, case law, tax treaties, legislative materials and … portal web ccg
26 CFR § 1.6664-4 - LII / Legal Information Institute
WebThe Internal Revenue Code of 1986 and Supreme Court decisions represent the highest tax authority beneath the U.S. Constitution. However, the Supreme Court does not establish law, but instead, simply interprets and applies the Code (and other authorities). Laura Li, a U.S. resident, worked for three months this summer in Hong Kong. Web2024-0696. Proposed rules on IRS supervisory approval requirements clarify timing and authority. The proposed regulations would give bright-line rules on who can approve certain penalty assessments and when they must do so. The clarifications resolve the conflicting court opinions that have interpreted the approval rules in an inconsistent manner. Websubstantial authority for such treatment, or (ii) any item if- (I) the relevant facts affecting the item's tax treatment are ... Substantial valuation misstatement under chapter 1. (1) In general. For purposes of this section , there is a substantial valuation misstatement under chapter 1 if- ... IRC Section 6662(d)(1)(A) irumbu thirai sinhala subtitle