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SEC 6653. ADDITIONS TO TAX FOR NEGLIGENCE AND FRAUD.
(a) Negligence.--
(1) In general.--If any part of any underpayment
(as defined in subsection (c)) is due to negligence or
disregard of rules or regulations, there shall be added
to the tax an amount equal to the sum of--
(A) 5 percent of the underpayment, and
(B) an amount equal to 50 percent of the
interest payable under section 6601 with respect
to the portion of such underpayment which is
attributable to negligence for the period
beginning on the last date prescribed by law for
payment of such underpayment (determined without
regard to any extension) and ending on the date of
the assessment of the tax (or, if earlier, the
date of the payment of tax).
(2) Underpayment taken into account reduced by
portion attributable to fraud.--There shall not be
taken into account under this subsection any portion of
an underpayment attributable to fraud with respect to
which a penalty is imposed under subsection (b).
* * * * * * *
(b) Fraud.--
(1) In general.--If any part of any underpayment
(as defined in subsection (c)) of tax required to be
shown on a return is due to fraud, there shall be added
to the tax an amount equal to the sum of--
(A) 75 percent of the portion of the
underpayment which is attributable to fraud, and
(B) an amount equal to 50 percent of the
interest payable under section 6601 with respect
to such portion for the period beginning on the
last day prescribed by law for payment of such
underpayment (determined without regard to any
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