§ 7702(f)(8)

secretary may waive the failure

UNDECIDED

0 of 4 settled

  1. 1

    § 7702(f)(8)

    ALL OF

    If the taxpayer establishes to the satisfaction of the Secretary that—

    “If the taxpayer establishes to the satisfaction of the Secretary that—” Opening words
    “the requirements described in subsection (a) for any contract year were not satisfied due to reasonable error, and” § 7702(f)(8)(A) unless Step 2 a life insurance contract UNDECIDED

    “Reasonable” implies facts and circumstances. No regulation cites this provision (eCFR, Oct 19, 2026)

    “reasonable steps are being taken to remedy the error,” § 7702(f)(8)(B)

    “Reasonable” implies facts and circumstances. No regulation cites this provision (eCFR, Oct 19, 2026)

    the Secretary may waive the failure to satisfy such requirements.

  2. 2

    § 7702(a)

    a life insurance contract

    ANY OF

    For purposes of this title, the term “life insurance contract” means any contract which is a life insurance contract under the applicable law, but only if such contract—

    “any contract which is a life insurance contract under the applicable law, but” Opening words
    “meets the cash value accumulation test of subsection (b), or” § 7702(a)(1)
    “meets the guideline premium requirements of subsection (c), and falls within the cash value corridor of subsection (d).” § 7702(a)(2)

    Step 3 a life insurance contract UNDECIDED

    Cases: Wickum v. Commissioner, T.C. Memo. 1998-270

  3. 3

    § 7702(a)(2)

    a life insurance contract

    ALL OF

    “any contract which is a life insurance contract under the applicable law, but” Enclosing § 7702(a)

    Cases: Wickum v. Commissioner, T.C. Memo. 1998-270

    “meets the guideline premium requirements of subsection (c), and” § 7702(a)(2)(A) needs Step 4 Contract meets the guideline premium requirements UNDECIDED
    “falls within the cash value corridor of subsection (d).” § 7702(a)(2)(B)
  4. 4

    § 7702(c)

    Contract meets the guideline premium requirements

    ALL OF
    “the sum of the premiums paid under such contract does not at any time exceed the guideline premium limitation as of such time”