4942 and 4945 would modify the rule for good-faith
determinations to expand the group of tax practitioners upon whose written advice a private foundation may base a good-faith
Court orders directing mediators to report a party's lack of good faith during the mediation process necessarily require a mediator to evaluate the actions, offers and counteroffers, and decisionmaking of the parties at mediation for the sole purpose of reporting to the court the absence of good-faith
With respect to charitable deduction property, the reasonable cause/good-faith
exception does not apply unless the taxpayer (1) based the claimed value of the property on a qualified appraisal made by a qualified appraiser and (2) made a good-faith
investigation of the value of the contributed property.
This can be done only if (a) the employee reports the special value on a timely filed federal income tax return; (b) the employee is not a control employee, or (c) the employer made a good-faith
mistake in applying the valuation rules.
6664-4(c) states that a taxpayer cannot rely on an opinion or advice to satisfy the reasonable-cause and good-faith
exception if he or she has not disclosed a (1) reportable transaction or (2) position based on a regulation being invalid.
10) The proposed regulations under section 6664 define reasonable-cause and good-faith
conduct in very broad and general terms: it is a facts-and-circumstances determination to be made on a case-by-case basis.
Furthermore, according to the committee report, disclosure of nonfrivolous positions (including a good-faith
challenge to the regulations) will "generally" prevent the imposition of the penalty.
ignorance of the law may be a defense in a tax case.
Instead, it has provided and extended a "good faith" period during which employers must follow the statute using a good-faith
The acknowledgment must also include the amount of the cash contribution or a description of noncash property contributed and the extent to which any goods or services were provided in return by the donee organization or charity, as well as a description and good-faith
estimate of the value of the goods or services provided.
3121(v)(2) and 3306(r)(2) (covering FICA and FUTA taxes on deferred compensation) are issued, the IRS will not challenge FICA and FUTA tax liability determinations by an employer if they are based on a reasonable, good-faith
interpretation of those sections.
The field directive states that sponsors of such plans may argue that, even if a provision excluding part-timers is not permitted for future years, such an exclusion is a reasonable good-faith
interpretation of Sec.