§6684 — Assessable penalties with respect to liability for tax under chapter 42
7 cases·3 followed·1 distinguished·3 cited—43% support
Statute Text — 26 U.S.C. §6684
If any person becomes liable for tax under any section of chapter 42 (relating to private foundations and certain other tax-exempt organizations) by reason of any act or failure to act which is not due to reasonable cause and either—
such person has theretofore been liable for tax under such chapter, or
such act or failure to act is both willful and flagrant,
then such person shall be liable for a penalty equal to the amount of such tax.
Treasury Regulations
- Treas. Reg. §Treas. Reg. §301.6684-1 Assessable penalties with respect to liability for tax under chapter 42
- Treas. Reg. §Treas. Reg. §301.6684-1(a) In general.
- Treas. Reg. §Treas. Reg. §301.6684-1(b) Showing of reasonable cause.
- Treas. Reg. §Treas. Reg. §301.6684-1(c) Willful and flagrant.
- Treas. Reg. §Treas. Reg. §301.6684-1(d) Effective date.
7 Citing Cases
- 3 - After concessions,3 the issues for,decision are : (1) Whether petitioner is liable for the section 6651(a)(1) addition to tax for 1998-2003 ; (2) whether petitioner is liable for the section 6651(a)(2) addition to tax for ,1998-2003 ; and (3) whether petitioner is liable for the section 6684(a) addition to tax for 1998-2003 .
GS OF FACT AND OPINION FOLEY, Judge: By notice dated September 8, 1999, respondent determined deficiencies in, and a penalty relating to, petitioner’s Federal excise taxes as follows: - 2 - Deficiencies Penalty Year Sec. 4941(a)(1)1 Sec. 4941(b)(1) Sec. 6684 1993 $ 9,894 -- -- 1994 14,156 -- -- 1995 17,531 -- -- 1996 20,756 -- -- 1997 23,981 -- -- 1998 27,206 -- -- 1999 30,431 $1,217,240 $1,361,195 The issue for determination is whether petitioner was a substantial contributor who engaged in pro