Treasury Regulations · 26 CFR
§ 1.6664-4T. Reasonable cause and good faith exception to section 6662 penalties.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 6664
Cite as 26 CFR § 1.6664-4T
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- February 9, 1996 by T.D. 8656
- Issued under
- 26 U.S.C. § 6664
- Length
- 144 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 1 regulation; cited by 1
¶(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 § 1.6662-6(d) apply. A taxpayer that does not satisfy the rules of § 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 § 1.6662-6(b). If the standards of the net section 482 penalty exclusion provisions under § 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]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
Cited by 1 other regulation
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 8656 (61 FR 4885)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Additions to the tax, additional amounts, and assessable penalties
Nearby sections
- § 1.6664-1 Accuracy-related and fraud penalties; definitions, effective date and special rules.
- § 1.6664-2 Underpayment.
- § 1.6664-3 Ordering rules for determining the total amount of penalties imposed.
- § 1.6664-4 Reasonable cause and good faith exception to section 6662 penalties.
- § 1.6664-4T Reasonable cause and good faith exception to section 6662 penalties.
- § 1.6694-0 Table of contents.
- § 1.6694-1 Section 6694 penalties applicable to tax return preparers.
- § 1.6694-2 Penalty for understatement due to an unreasonable position.
- § 1.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.