[Code of Federal Regulations]
[Title 26, Volume 13]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR]

[Page 516]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
Procedure and Administration--Table of Contents
 
Sec.  1.6664-4T  Reasonable cause and good faith exception to section 
6662 penalties.

    (a)-(e) [Reserved]
    (f) Transactions between persons described in section 482 and net 
section 482 transfer price adjustments. For purposes of applying the 
reasonable cause and good faith exception of section 6664(c) to net 
section 482 adjustments, the rules of Sec.  1.6662-6(d) apply. A 
taxpayer that does not satisfy the rules of Sec.  1.6662-6(d) for a net 
section 482 adjustment cannot satisfy the reasonable cause and good 
faith exception under section 6664(c). The rules of this section apply 
to underpayments subject to the transactional penalty in Sec.  1.6662-
6(b). If the standards of the net section 482 penalty exclusion 
provisions under Sec.  1.6662-6(d) are met with respect to such 
underpayments, then the taxpayer will be considered to have acted with 
reasonable cause and good faith for purposes of this section.

[T.D. 8656, 61 FR 4885, Feb. 9, 1996]