Post-1984 letter rulings may be substantial authority for purposes of the accuracy-related penalty in § 6662.

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Post-1984 letter rulings can be considered substantial authority for purposes of the accuracy-related penalty under § 6662. This means that if a taxpayer relies on a post-1984 letter ruling in taking a tax position, they may be able to avoid the penalty if the IRS disagrees with their position. However, it's important to note that there are other criteria that must be met for a taxpayer to claim substantial authority, and the IRS retains the right to challenge a taxpayer's position in court.

Post-1984 Letter Rulings May Be Substantial Authority for Purposes of the Accuracy-Related