Rev. & Tax. Code, § 19164.5 · Article 7. Penalties and Additions to Tax
Rev. & Tax. Code, § 19164.5
Text — As published in the Legislative Counsel's database, tables dated October 18, 2026 (pubinfo_2025.zip)
(a) A reportable transaction accuracy-related penalty shall be imposed under this part and shall be determined in accordance with Section 6662A of the Internal Revenue Code, relating to the imposition of an accuracy-related penalty on understatements with respect to reportable transactions, except as otherwise provided.
(b) (1) The reportable transaction understatement, as determined under Section 6662A(b) of the Internal Revenue Code, is modified to not include amounts to which the penalty of Section 19774 is imposed.
(2) Section 6662A(b)(1)(A)(ii) of the Internal Revenue Code is modified to substitute the phrase “Sections 17041, 23151, 23181, or 23501” for “section 1 (section 11 in the case of a taxpayer which is a corporation).”
(3) Section 6662A(b)(1)(B) of the Internal Revenue Code is modified to substitute the phrase “Part 10 (commencing with Section 17001) or Part 11 (commencing with Section 23001)” for “subtitle A.”
(4) Section 6662A(b)(2)(B) of the Internal Revenue Code is modified to substitute the phrase “income or franchise tax” for “Federal income tax.”
(5) Section 6662A(e)(1) of the Internal Revenue Code is modified to additionally provide that the amount of the understatement is increased by noneconomic transaction understatements, as defined in Section 19774.
(c) Section 6662A(e)(2) of the Internal Revenue Code is modified to additionally provide that Section 6662A of the Internal Revenue Code does not apply to amounts to which a penalty is imposed under Section 19774.
(d) The provisions of subdivision (f) of Section 19772, relating to the rescission of the penalty by the Chief Counsel, shall apply to any penalty imposed by this section.
Notes and commentary — not statutory text
History
Added by Stats. 2005, Ch. 691, Sec. 47.2. Effective October 7, 2005.
Source of truth
- Edition
- As published in the Legislative Counsel's database, tables dated October 18, 2026 (pubinfo_2025.zip)
- Official file
- https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC§ionNum=19164.5.
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- sha256 3c3ebb9f1139236b5b2e23cf986631a6c01d9f323e25947b845677cf7a1b3473
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- compose_ca.py 2026-10-22: the Legislative Counsel's CAML content files read by a tokenizer (caml_readers.reader_a); an independent xml.etree reading (caml_readers.reader_b) agrees on every section
This section cites
Provisions in this library that the text above cites, as it prints each citation. A range cited as “ss. 61.13-61.16” links its first and last provisions.
Revenue and Taxation Code
- Rev. & Tax. Code, div. 2, pt. 10PERSONAL INCOME TAXPrinted as Part 10 (commencing with Section 17001)
- Rev. & Tax. Code, § 17041Printed as Sections 17041, 23151, 23181, or 23501
- Rev. & Tax. Code, § 19772Printed as Section 19772
- Rev. & Tax. Code, § 19774Printed as Section 19774
- Rev. & Tax. Code, div. 2, pt. 11CORPORATION TAX LAWPrinted as Part 11 (commencing with Section 23001)
- Rev. & Tax. Code, § 23151Printed as Sections 17041, 23151, 23181, or 23501
- Rev. & Tax. Code, § 23181Printed as Sections 17041, 23151, 23181, or 23501
- Rev. & Tax. Code, § 23501Printed as Sections 17041, 23151, 23181, or 23501
Cited by 3 provisions
Provisions in this library whose text cites Rev. & Tax. Code, § 19164.5. Each shows the citation as that text prints it.
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