§1821
15 cases·5 followed·10 cited—33% support
Statute Text — 26 U.S.C. §1821
Statute text not available for this section.
15 Citing Cases
1821 (2012); (4) pay the fees and allowances described in that section, see sec. 7466(a)(1); and (5) award reimbursement for reasonable expenses, see 28 U.S.C. sec. 361. The trend in the evolution ofthe Tax Court's governing statutes from 1969 to 2015 is clear: Congress has continued to provide authority and design to the Tax Court more like t
* * * * * * * (b) Fraud.--If any part of any underpayment (as defined in subsection (c)) 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.
019(b); and generally for other taxes where tax returns or lists were filed by section 3612(d)(2). As to the applicability of section 3612(d)(2) to estate taxes, see sec. 871(i). The civil fraud addition to tax for various stamp taxes was imposed by section 1821(a)(3). When the Internal Revenue Code of 1954 was enacted, the foregoing 1939 Code provisions were replaced by the following: SEC. 6653. FAILURE TO PAY TAX. (b) Fraud. — If any part of any underpayment (as defined in subsection (c)) of t