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(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
extension) and ending on the date of the
assessment of the tax or, if earlier, the date of
the payment of the tax.
For 1988, the applicable provision was in essence the same
as the above section 6653(b)(1)(A). For 1989 through 1993,
section 6651 provides in pertinent part:
SEC. 6651. FAILURE TO FILE TAX RETURN OR TO PAY
TAX.
(a) Addition to the Tax.--In case of failure-–
(1) to file any return required under
authority of subchapter A of chapter 61 (other
than part III thereof), subchapter A of chapter 51
(relating to distilled spirits, wines, and beer),
or of subchapter A of chapter 52 (relating to
tobacco, cigars, cigarettes, and cigarette papers
and tubes) or of subchapter A of chapter 53
(relating to machine guns and certain other
firearms), on the date prescribed therefor
(determined with regard to any extension of time
for filing), unless it is shown that such failure
is due to reasonable cause and not due to willful
neglect, there shall be added to the amount
required to be shown as tax on such return 5
percent of the amount of such tax if the failure
is for not more than 1 month, with an additional
5 percent for each additional month or fraction
thereof during which such failure continues, not
exceeding 25 percent in the aggregate;
* * * * * * *
(f) Increase in Penalty for Fraudulent Failure to
File.--If any failure to file any return is fraudulent,
paragraph (1) of subsection (a) shall be applied-–
(1) by substituting “15 percent” for
“5 percent” each place it appears, and
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