Code of Federal Regulations · Section
§ 301.6404-0 — -0 Table Of Contents
26 C.F.R. § 301.6404-0
This section lists the paragraphs contained in §§ 301.6404-1 through 301.6404-4.
(a) In general.
(b) Ministerial act.
(1) Definition.
(2) Examples.
(c) Effective date.
(a) General rule.
(b) Requirements.
(1) In general.
(2) Advice was reasonably relied upon.
(i) In general.
(ii) Advice relating to a tax return.
(iii) Amended returns.
(iv) Advice not related to a tax return.
(v) Period of reliance.
(3) Advice was in response to written request.
(4) Taxpayer's information must be adequate and accurate.
(c) Definitions.
(1) Advice.
(2) Penalty and addition to tax.
(d) Procedures for abatement.
(e) Period for requesting abatement.
(f) Examples.
(g) Effective date.
(a) Suspension.
(1) In general.
(2) Treatment of amended returns and other documents.
(i) Amended returns filed on or after December 21, 2005, that show an increase in tax liability.
(ii) Amended returns that show a decrease in tax liability.
(iii) Amended returns and other documents as notice.
(iv) Joint return after filing separate return.
(3) Separate application.
(4) Duration of suspension period.
(5) Certain notices provided on or after November 26, 2007.
(i) Eighteen-month period has closed.
(ii) All other cases.
(6) Examples.
(7) Notice of liability and the basis for the liability.
(i) In general.
(ii) Tax attributable to TEFRA partnership items.
(iii) Examples.
(8) Providing notice.
(i) In general.
(ii) Providing notice in TEFRA partnership proceedings.
(b) Exceptions.
(1) Failure to file tax return or to pay tax.
(2) Fraud.
(3) Tax shown on return.
(4) Gross misstatement.
(i) Description.
(ii) Effect of gross misstatement.
(5) Listed transactions and undisclosed reportable transactions.
(i) In general.
(ii) Special rule for certain listed or undisclosed reportable transactions.
(A) Participant in a settlement initiative.
(1) Participant in a settlement initiative who as of January 23, 2006, had not reached agreement with the IRS.
(2) Participant in a settlement initiative who, as of January 23, 2006, had reached agreement with the IRS.
(B) Taxpayer acting in good faith.
(1) In general.
(2) Presumption.
(3) Examples.
(C) Closed transactions.
(c) Special rules.
(1) Tentative carryback and refund adjustments.
(2) Election under section 183(e).
(i) In general.
(ii) Example.
(d) Effective/applicability date.
Authorizing Statute
-
Confidentiality and disclosure of returns and return information26 U.S.C. § 6103
-
Restrictions applicable to deficiencies; petition to Tax Court26 U.S.C. § 6213
-
Signing of returns and other documents26 U.S.C. § 6061
-
Assessment, collection, and payment26 U.S.C. § 6232
-
Period of limitations on making adjustments26 U.S.C. § 6235
-
Validity and priority against certain persons26 U.S.C. § 6323
-
Definitions26 U.S.C. § 7701
-
Partner’s return must be consistent with partnership return26 U.S.C. § 6222
-
Alternative to payment of imputed underpayment by partnership26 U.S.C. § 6226
-
Notice of qualification as executor or receiver26 U.S.C. § 6036
-
Partners bound by actions of partnership26 U.S.C. § 6223
-
Abatements26 U.S.C. § 6404
-
Commissioner of Internal Revenue; other officials26 U.S.C. § 7803
-
Extension of time for filing returns26 U.S.C. § 6081
-
Treaty-based return positions26 U.S.C. § 6114
-
Timely mailing treated as timely filing and paying26 U.S.C. § 7502
-
Interest and penalties26 U.S.C. § 6233
-
Certified professional employer organizations26 U.S.C. § 7705
-
Accelerated cost recovery system26 U.S.C. § 168
-
General requirement of return, statement, or list26 U.S.C. § 6011
-
Disclosure of reportable transactions26 U.S.C. § 6111
-
Rules and regulations26 U.S.C. § 7805
-
Persons required to make returns of income26 U.S.C. § 6012
-
Return of S corporation26 U.S.C. § 6037
-
Reimbursement to State and local law enforcement agencies26 U.S.C. § 7624
-
Determination at partnership level26 U.S.C. § 6221
-
Partnership adjustment by Secretary26 U.S.C. § 6225
-
Authority to release levy and return property26 U.S.C. § 6343
-
Disclosure or use of information by preparers of returns26 U.S.C. § 7216
-
Departmental regulations5 U.S.C. § 301
-
Tax imposed26 U.S.C. § 1
-
Notice of proceedings and adjustment26 U.S.C. § 6231
-
Payment of tax by commercially acceptable means26 U.S.C. § 6311
-
Sale of seized property26 U.S.C. § 6335
-
Procedural requirements26 U.S.C. § 6751
-
Low-income housing credit26 U.S.C. § 42
-
Special rules26 U.S.C. § 1474
-
Returns by exempt organizations26 U.S.C. § 6033
-
Definitions and special rules26 U.S.C. § 6241
-
Administrative appeal of liens26 U.S.C. § 6326
-
Expenses of detection of underpayments and fraud, etc.26 U.S.C. § 7623
-
Information concerning resident status26 U.S.C. § 6039E
-
Identifying numbers26 U.S.C. § 6109
-
Administrative adjustment request by partnership26 U.S.C. § 6227
-
Authority to make credits or refunds26 U.S.C. § 6402
-
Judicial review of partnership adjustment26 U.S.C. § 6234
-
Failure to file notice of redetermination of foreign tax26 U.S.C. § 6689
-
Income from discharge of indebtedness26 U.S.C. § 108