Review of the Civil Penalty Provisions Contained in the Internal Revenue Code: Hearings Before the Subcommittee on Oversight of the Committee on Ways and Means, House of Representatives, One Hundred First Congress, First Session on Recommendations for Civil Tax Penalty Reform and H.R. 2528 ... February 21 and June 6, 1989
U.S. Government Printing Office, 1989 - Internal revenue law - 423 pages
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addition administration amended amount apply appropriate believe better bill cause Chairman Pickle changes civil Code Commissioner Committee compliance comply concern conduct consider correct Court determine disclose disclosure due diligence effective effort encourage example existing fact failed failure fair fraud fund going IMPACT important imposed improve income increase information reporting information returns interest Internal Revenue Code Internal Revenue Service issue Judge legislation litigation means negligence payors penalty penalty provisions percent person position possible practice practitioner preparer present problems proposed question reasonable recommendations reform regulations relating representatives respect RESPONSE result rules sanctions Service specific standard statement structure Subcommittee substantial authority suggest Task Force Tax Court tax law tax penalty tax return taxpayer Thank understand understatement views
Page 173 - AMENDMENT OF 1954 CODE. — Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1954.
Page 105 - ... shall impose upon the person who signed it, a represented party, or both, an appropriate sanction, which may include an order to pay to the other party or parties the amount of the reasonable expenses incurred because of the filing of the pleading, motion, or other paper, including a reasonable attorney's fee.
Page 225 - 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 50 percent of the underpayment, but no delinquency penalty shall be assessed with respect to the same underpayment (section 6653, IRC).
Page 104 - The signature of an attorney constitutes a certificate by him that he has read the pleading; that to the best of his knowledge, information, and belief there is good ground to support it; and that it is not interposed for delay.
Page 105 - ... well grounded in fact and is warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law, and that it is not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation.
Page 252 - Whenever It appears to the Tax Court that proceedings before It have been Instituted by the taxpayer merely for delay, damages in an amount not in excess of $500 shall be awarded to the United States by the Tax Court in its decision.
Page 251 - For purposes of subsection (a), the amount of tax required to be shown on the return shall be reduced by the amount of any part of the tax which is paid on or before the date prescribed for payment of the tax and by the amount of any credit against the tax which may be claimed upon the return.
Page 324 - In addition, a similar provision was added to the Internal Revenue Code by the Tax Reform Act of 1969.
Page 230 - understatement" of income tax is the excess of the tax required to be shown on the return, over the tax shown on the return (reduced by any rebates of tax).