1.148-3A—General arbitrage rebate rules.
(h)
(3) Waivers of the penalty.
For purposes of § 1.148-3(h)(3), willful neglect does not include a failure that is attributable solely to the permissible retroactive selection of a short first bond year if the rebate amount that the issuer failed to pay is paid within 60 days of the selection of that bond year.