{"database": "openregs", "table": "federal_register", "rows": [["03-31899", "Establishing Defenses to the Imposition of the Accuracy-Related Penalty", "Rule", "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.", "2003-12-30", 2003, 12, "https://www.federalregister.gov/documents/2003/12/30/03-31899/establishing-defenses-to-the-imposition-of-the-accuracy-related-penalty", "https://www.govinfo.gov/content/pkg/FR-2003-12-30/pdf/03-31899.pdf", "Treasury Department; Internal Revenue Service", "497,254", "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...", "1545-AY97"]], "columns": ["document_number", "title", "type", "abstract", "publication_date", "pub_year", "pub_month", "html_url", "pdf_url", "agency_names", "agency_ids", "excerpts", "regulation_id_numbers"], "primary_keys": ["document_number"], "primary_key_values": ["03-31899"], "units": {}, "query_ms": 0.6402040016837418, "source": "Federal Register API & Regulations.gov API", "source_url": "https://www.federalregister.gov/developers/api/v1", "license": "Public Domain (U.S. Government data)", "license_url": "https://www.regulations.gov/faq"}