- 11 - 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".Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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