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Revised: 6503 - Limited qualifying expense (Tax Year prior to 2021)
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Revised: 5627 - Statutory adjustment to QBID based upon other return changes made (3) This IRM has been updated to incorporate the provisions of Interim Guidance SBSE-04-0821-0034, by revising, adding and removing the following standard explanations to Exhibit 4.10.10-2, Standard Explanations: Removed: 8140 - Failure to Pay/Failure to File Īdded: 8142 - Accuracy-Related Penalty – Substantial Valuation MisstatementĪdded: 8143 - Accuracy-Related Penalty – Reportable Transaction Understatement – UndisclosedĪdded: 8144 - Accuracy-Related Penalty Transaction Lacking Economic SubstanceĪdded: 8145 - Accuracy-Related Penalty – Underpayment Attributable to Undisclosed Foreign Financial Asset UnderstatementĪdded: 8146 - Income Tax Valuation Misstatements – Gross valuation misstatement – 400 percent or more (or 25 percent or less) of corrected amount under section 482Īdded: 8147 - Income Tax Valuation Misstatements – Gross valuation misstatement – net section 482 transfer price adjustmentĪdded: 8148 - Accuracy-Related Penalty – Nondisclosed Noneconomic Substance TransactionsĪdded: 8149 - Accuracy-Related Penalty due to Undisclosed Foreign Financial Asset Understatement IRC 6662(j) based on 6662(b)(7) Removed: 8135 - Accuracy-Related Penalty
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Removed: 8111 - Failure to File 5 percent month Removed: 8110 - Failure to File 4.5 percent month/previously assessed penalty considered Removed: 8109 - Assert fraud and delete delinquency – Removed: 8101 - Delinquent with no reasonable cause/Failure to File-5 percent month Revised: 8141 - Erroneous Claim for Refund or Credit Penalty Revised: 8139 - Accuracy-Related Penalty – Reportable Transaction Understatement – Disclosed Revised: 8137 - Reduction of Fraudulent Failure to File addition to tax Revised: 8134 - Removed Fraudulent Failure to File Revised: 8133 - Fraudulent failure to file changed to failure to file Revised: 8127 - Accuracy-Related Penalty – Gross Valuation Misstatement of Pension Liabilities Revised: 8126 - Accuracy-Related Penalty – Gross Estate or Gift Tax Valuation Understatement Revised: 8125 - Income Tax Valuation Misstatements – Gross Valuation Misstatement Revised: 8124 - Accuracy-Related Penalty due to substantial understatement of income tax Revised: 8122 - Fraudulent Failure to File Revised: 8121 - Reduction of Failure to File Addition to Tax Revised: 8119 - Reduction of Addition to Tax for Failure to Pay sufficient Estimated Tax Revised: 8115 - Failure to File - 5 percent month/prev. Revised: 8112 - Removal of Failure to File addition to tax
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Revised: 8103 - Negligence Penalty or Disregard of Rules or Regulations