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  1. An accuracy-related penalty applies to various understatements, including “substantial” understatements and those due to negligence.3 If the understatement exceeds the substantial …

  2. 20.1.5 Return Related Penalties | Internal Revenue Service

    The penalty rate increases to 40 percent in certain circumstances involving gross valuation misstatements, nondisclosed noneconomic substance transactions, and undisclosed foreign …

  3. §6701. Penalties for aiding and abetting understatement of ...

    26 USC 6701: Penalties for aiding and abetting understatement of tax liabilityText contains those laws in effect on July 11, 2025 From Title 26-INTERNAL REVENUE CODESubtitle F …

  4. eCFR :: 26 CFR 1.6662-4 -- Substantial understatement of ...

    (2) Understatements for carryback years not reduced by amount of carrybacks. The amount of an understatement for a carryback year is not reduced on account of a carryback of a loss, …

  5. Internal Revenue Bulletin: 2022-50 | Internal Revenue Service

    2022年12月12日 · The penalty rate increases to 40 percent in the case of gross valuation misstatements under section 6662 (h), nondisclosed noneconomic substance transactions …

  6. §6694. Understatement of taxpayer's liability by income tax ...

    (a) Understatements due to unrealistic positions If- (1) any part of any understatement of liability with respect to any return or claim for refund is due to a position for which there was not a …

  7. U.S.C. Title 26 - INTERNAL REVENUE CODE - GovInfo

    Amendment by section 1409 (c) (2) of Pub. L. 111–152 applicable to understatements attributable to transactions entered into after Mar. 30, 2010, see section 1409 (e) (3) of Pub. L. 111–152, …