Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polacheck, Co-Executors - Page 11

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          applied thereto.  The reason for the change, as stated by the               
          House Committee on the Budget, was:                                         
                    The committee believes that the number of                         
               different penalties that relate to accuracy of a tax                   
               return, as well as the potential for overlapping among                 
               many of these penalties, causes confusion among                        
               taxpayers and leads to difficulties in administering                   
               these penalties by the IRS.  Consequently, the                         
               committee has revised these penalties and consolidated                 
               them.  The committee believes that its changes will                    
               significantly improve the fairness, comprehensibility,                 
               and administrability of these penalties.  [H. Rept.                    
               101-247, at 2221 (1989).]                                              
               Our interpretation of the relevant phrase is also supported            
          by Congress' recognition of the fact that some taxes are payable            
          by return and that other taxes are payable by stamp.  Section               
          6511(a), for example, provides different limitations for credit             
          or refund, depending on whether it is "in respect of which tax              
          the taxpayer is required to file a return * * * [or] which is               
          required to be paid by means of a stamp".  Likewise, section                
          6601(a) imposes interest on "any amount of tax imposed by this              
          title (whether required to be shown on a return, or to be paid by           
          stamp or by some other method) [that] is not paid on or before              
          the last day prescribed for payment".  Similarly, section 6501(a)           
          generally provides that "the amount of any tax imposed by this              
          title shall be assessed within 3 years after the return was filed           
          * * * or, if the tax is payable by stamp, at any time after such            
          tax became due and before the expiration of 3 years after the               
          date on which any part of such tax was paid".                               





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