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2395, repealed section 6661 and replaced it with section 6662.
Section 6664 was also enacted, defining the term “underpayment”.
Sections 6662(a) and 6664(a) provide, in pertinent part, as
follows:
SEC. 6662. IMPOSITION OF ACCURACY RELATED PENALTY ON
UNDERPAYMENTS.
(a) Imposition of Penalty.--If this section
applies to any portion of an underpayment of tax
required to be shown on a return, there shall be added
to the tax an amount equal to 20 percent of the portion
of the underpayment to which this section applies.
* * * * * * *
SEC. 6664. DEFINITIONS AND SPECIAL RULES.
(a) Underpayment.--For purposes of this part, the
term “underpayment” means the amount by which any tax
imposed by this title exceeds the excess of–-
(1) the sum of--
(A) the amount shown as the
tax by the taxpayer on his return,
plus
(B) amounts not so shown
previously assessed (or collected
without assessment), over
(2) the amount of rebates made. [Emphasis added.]
Section 1.6664-2(d), Income Tax Regs., provides further guidance
regarding the phrase “collected without assessment” in section
6664(a)(1)(B):
(d) Amounts not so shown previously assessed (or
collected without assessment). * * * For purposes of
[defining an underpayment for purposes of section
6662], the amount "collected without assessment" is the
amount by which the total of the credits allowable
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