IRC section 6662 imposes accuracy
related penalties for substantial understatement of tax liability
or negligence or disregard of rules and regulations. Section 6694
imposes similar penalties on return preparers. Regulations section
1.6662-4(e) and (f) provide for reduction of these penalties if
adequate disclosure of the tax treatment is made on Form 8275 or,
if the position is contrary to a regulation on Form
8275-R.
US Code:
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USC 6662 Name of Law: Imposition of accuracy-related penalty on
underpayments
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.