2016 US Code
Title 26 - Internal Revenue Code
Subtitle F - Procedure and Administration
Chapter 68 - Additions to the Tax, Additional Amounts, and Assessable Penalties
Subchapter A - Additions to the Tax and Additional Amounts
Part II - Accuracy-Related and Fraud Penalties
Sec. 6663 - Imposition of fraud penalty

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Citation 26 U.S.C. § 6663 (2016)
Section Name §6663. Imposition of fraud penalty
Section Text (a) Imposition of penalty

If any part of any underpayment of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 75 percent of the portion of the underpayment which is attributable to fraud.

(b) Determination of portion attributable to fraud

If the Secretary establishes that any portion of an underpayment is attributable to fraud, the entire underpayment shall be treated as attributable to fraud, except with respect to any portion of the underpayment which the taxpayer establishes (by a preponderance of the evidence) is not attributable to fraud.

(c) Special rule for joint returns

In the case of a joint return, this section shall not apply with respect to a spouse unless some part of the underpayment is due to the fraud of such spouse.

Source Credit

(Added Pub. L. 101–239, title VII, §7721(a), Dec. 19, 1989, 103 Stat. 2397.)

Publication Title United States Code, 2012 Edition, Supplement 4, Title 26 - INTERNAL REVENUE CODE
Category Bills and Statutes
Collection United States Code
SuDoc Class Number Y 1.2/5:
Contained Within Title 26 - INTERNAL REVENUE CODE
Subtitle F - Procedure and Administration
CHAPTER 68 - ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES
Subchapter A - Additions to the Tax and Additional Amounts
PART II - ACCURACY-RELATED AND FRAUD PENALTIES
Sec. 6663 - Imposition of fraud penalty
Contains section 6663
Date 2016
Laws In Effect As Of Date January 6, 2017
Positive Law No
Disposition standard
Statutes at Large Reference 103 Stat. 2397
Public Law References Public Law 101-239
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