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 Hundredth Congress, Second Session, March 31; and July 28, 1988, Volume 4

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Page 487 - The American Bankers Association is the national trade and professional association for America's commercial banks, from the smallest to the largest. ABA members represent about 90 percent of the industry's total assets.
Page 24 - However, the negligence penalty extends by reason of such negligence to only that portion of the understatement attributable to the misreported item. The civil fraud penalty generally is imposed only when the taxpayer's behavior extends substantially beyond a failure to take reasonable care in the preparation of the required return and involves an intentional or reckless underpayment of taxes owed. This penalty is currently equal to 75 percent of the portion of the underpayment attributable to fraud,...
Page 433 - Thank you again for the opportunity to appear before you today. And I will be happy to answer any questions that you may have at the appropriate time.
Page 352 - They are provided primarily as a safeguard for the protection of the revenue and to reimburse the Government for the heavy expense of investigation and the loss resulting from the taxpayer's fraud.
Page 598 - ... to the best of the signer's knowledge, information, and belief formed after reasonable inquiry it is well grounded in fact and is warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law...
Page 587 - ... penalties" or also to civil penalties as well. In approving the provisions dealing with fines and similar penalties in 1969, it was the intention of the committee to disallow deductions for payments of sanctions which are imposed under civil statutes but which in general terms serve the same purpose as a fine exacted under a criminal statute. The provision was intended to apply, for example, to penalties provided for under the Internal Revenue Code in the form of assessable penalties (subchapter...
Page 590 - If any amount of tax imposed by this title (whether required to be shown on a return, or to be paid by stamp or by some other method) is not paid on or before the last date prescribed for payment. interest on such amount at the rate of 6 percent per annum shall be paid for the period from such last date to the date paid.
Page 385 - Willfully aids or assists in, or procures, counsels, or advises the preparation or presentation under, or in connection with any matter arising under, the internal revenue laws, of a return, affidavit, claim, or other document, which is fraudulent or is false as to any material matter, whether or not such falsity or fraud is with the knowledge or consent of the person authorized or required to present such return, affidavit, claim, or document; . . . shall be guilty of a felony...
Page 586 - If in a criminal proceeding a taxpayer is convicted of a violation of the antitrust laws, or his plea of guilty or nolo contendere to an indictment or information charging such a violation is entered or accepted in such a proceeding, no deduction...
Page 361 - The fraud meant is actual, intentional wrongdoing, and the intent required is the specific purpose to evade a tax believed to be owing.

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