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All Federal Register documents (rules, proposed rules, notices, presidential documents) from 1994 to present.

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts
02-32927 Establishing Defenses to the Imposition of the Accuracy-Related Penalty Proposed Rule This document contains proposed regulations that limit the defenses available to the imposition of the accuracy-related penalty when taxpayers fail to disclose reportable transactions or fail to disclose that they have taken a position on a return based upon a regulation being invalid. By limiting a taxpayer's ability to use an opinion or advice from a tax professional as a basis for a defense, the proposed regulations are intended to promote the disclosure of reportable transactions and positions by taxpayers that conflict with regulations issued by the Secretary. The proposed regulations also clarify the existing regulations with respect to the facts and circumstances that the IRS will consider in determining whether a taxpayer acted with reasonable cause and in good faith in relying on an opinion or advice. 2002-12-31 2002 12 https://www.federalregister.gov/documents/2002/12/31/02-32927/establishing-defenses-to-the-imposition-of-the-accuracy-related-penalty https://www.govinfo.gov/content/pkg/FR-2002-12-31/pdf/02-32927.pdf Treasury Department; Internal Revenue Service 497,254 This document contains proposed regulations that limit the defenses available to the imposition of the accuracy-related penalty when taxpayers fail to disclose reportable transactions or fail to disclose that they have taken a position on a return...

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  • 0 rows from fr_document_number in fr_regs_crossref
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