These regulations provide guidance
about substantial and gross valuation misstatements as defined in
sections 6662(e) and 6662(h). They also provide guidance about the
reasonable cause and good faith exclusion. The regulations apply to
taxpayers who have transactions between persons described in
section 482 and not section 482 transfer price
adjustments.
US Code:
26 USC 6662 (e) Name of Law: Substantial valuation misstatement
under chapter 1
US Code:
26 USC 6662 (a) Name of Law: Imposition of Penalty
Gregory Spring 202 435-5265
gregory.a.spring@irscounsel.treas.gov
No
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.