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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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