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The phrase “tax required to be shown on a return” is described in
the committee report as “all taxes for which returns are
required”. S. Rept. 83-1622 at 591. That phrase is used to set
off the section 6653(b), I.R.C. 1954 rules from the rules
applying to “any tax imposed by this title which is payable by
stamp, coupons, tickets, books, or other devices”, which are
collectively referred to in the committee report as “any stamp
tax” S. Rept. 83-1622, at 591, and which appear in the statute at
section 6653(e), I.R.C. 1954.
The classification interpretation is clear from the
legislative events of 1954 and the committee reports. One
searches in vain for any legislative events of 1954 or
explanations in the course of the enactment of the 1954 Code that
suggests that the phrase in dispute should be given a temporal
interpretation, whether as to fraud or in general.
SWIFT, PARR, WHALEN, LARO, VASQUEZ, GALE, and MARVEL, JJ.,
agree with this concurring opinion.
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