ADMINISTRATIVE

REG–126016–01, page 486. Proposed regulations under sections 6662 and 6664 of the Code limit the defenses available to the imposition of the accuracyrelated penalty when taxpayers fail to disclose reportable transactions or that they have taken a position based upon a regulation being invalid. The regulations also clarify existing regulations with respect to the facts and circumstances that the IRS will consider in determining whether a taxpayer acted with reasonable cause and in good faith in relying on an opinion or advice.

Announcement 2003–9, page 490. This document contains corrections to proposed regulations (REG–150313–01, 2002–44 I.R.B. 777) under sections 302, 304, and other sections of the Code providing guidance regarding the treatment of the basis of redeemed stock when a distribution in redemption of such stock is treated as a dividend.

February 18, 2003 2003–7 I.R.B.