2019 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 (2019)
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.)

Editorial Notes EFFECTIVE DATE

Section applicable to returns the due date for which (determined without regard to extensions) is after Dec. 31, 1989, see section 7721(d) of Pub. L. 101–239, set out as an Effective Date of 1989 Amendment note under section 461 of this title.

Publication Title United States Code, 2018 Edition, Supplement 1, 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 2019
Laws In Effect As Of Date January 24, 2020
Positive Law No
Disposition standard
Statutes at Large References 103 Stat. 2397
Public Law References Public Law 101-239
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