# Establishing Defenses to the Imposition of the Accuracy-Related Penalty
> **IRS** · Final regulations. · Published 2003-12-30 · Effective 2003-12-30 · 68 FR 75126
## Document
- **Document number:** 03-31899
- **Category:** other
- **Sub-agency:** IRS
- **Federal Register citation:** 68 FR 75126
- **CFR reference:** 26 CFR 1
- **Publication date:** 2003-12-30
- **Effective date:** 2003-12-30
- **Treasury docket:** TD 9109
## Abstract

This document contains final regulations that affect the defenses available to the imposition of the accuracy-related penalty when taxpayers fail to disclose reportable transactions or fail to disclose that they have taken a return position based on the conclusion that a regulation is invalid. The final regulations are intended to promote disclosure of reportable transactions and positions based on the conclusion that a regulation is invalid by narrowing a taxpayer's ability to establish good faith and reasonable cause as a defense. The final regulations also clarify the existing regulations with respect to the facts and circumstances to be considered in determining whether a taxpayer acted with reasonable cause and in good faith.

## Source
- [Federal Register document](https://www.federalregister.gov/documents/2003/12/30/03-31899/establishing-defenses-to-the-imposition-of-the-accuracy-related-penalty)
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