2014—Subsec. (c). Pub. L. 113–295 substituted “section 6664(d)(3)(A)” for “section 6664(d)(2)(A)”.
2010—Subsec. (e)(2)(B). Pub. L. 111–152 substituted “certain increased underpayment penalties” for “gross valuation misstatement penalty” in heading and “subsections (h) or (i) of section 6662” for “section 6662(h)” in text. See Codification note above.
2005—Subsec. (e)(2). Pub. L. 109–135 reenacted heading without change and amended text generally. Prior to amendment, text read as follows:
“(A) Application of fraud penalty.—References to an underpayment in section 6663 shall be treated as including references to a reportable transaction understatement.
“(B) No double penalty.—This section shall not apply to any portion of an understatement on which a penalty is imposed under section 6663.
“(C) Coordination with valuation penalties.—
“(i) Section 6662(e).—Section 6662(e) shall not apply to any portion of an understatement on which a penalty is imposed under this section.
“(ii) Section 6662(h).—This section shall not apply to any portion of an understatement on which a penalty is imposed under section 6662(h).”
Statutory Notes and Related Subsidiaries
Report on Tax Shelter Penalties and Certain Other Enforcement Actions
Pub. L. 111–240, title II, § 2103, Sept. 27, 2010, 124 Stat. 2564, provided that:
“(a) In General.—The Commissioner of Internal Revenue, in consultation with the Secretary of the Treasury, shall submit to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate an annual report on the penalties assessed by the Internal Revenue Service during the preceding year under each of the following provisions of the Internal Revenue Code of 1986:
Section 6700(a) (relating to promoting abusive tax shelters
“(b) Additional Information.—The report required under subsection (a) shall also include information on the following with respect to each year:
Any extension of the time for assessment of tax enforced, or assessment of any amount under such an extension, under paragraph (10) of section 6501(c) of the Internal Revenue Code of 1986
“(c) Date of Report.—
The first report required under subsection (a) shall be submitted not later than December 31, 2010.”