26 U.S. Code § 6663 - Imposition of fraud penalty
If the Secretary establishes that any portion of an underpayment is attributable to fraud, the entire underpayment shall be treated as attributable to fraud, except with respect to any portion of the underpayment which the taxpayer establishes (by a preponderance of the evidence) is not attributable to fraud.
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.
Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.
We truncate results at 20000 items. After that, you're on your own.
- Erroneous claim for refund or credit : 2016-09-30
- Definition of Underpayment : 2016-09-30
- Fraud Penalty : 2016-09-30
- Definition of Underpayment : 2015-11-06
- Increase in Penalty for Fraudulent Failure to File : 2015-11-06
- Fraud Penalty : 2015-11-06
- Necessity for Notice of Deficiency : 2015-11-06
- Definition of Underpayment : 2015-10-23
- Fraud Penalty : 2015-10-23
- Fraud Penalty : 2010-12-03
- Action for Recovery of Erroneous Refunds : 2009-06-05
- Fraud Penalty : 2009-06-05
- Person Liable : 2009-06-05
- Intent v. No Intent to Defraud : 2001-06-29
- Fraud Penalty : 2001-06-29
- Burden of Proof Taxpayer v. Commissioner : 2001-06-29
- Accuracy-related penalty : 2001-05-11
- Definition of Underpayment : 2001-05-11
- Fraud Penalty : 2001-05-11
- Accuracy-related penalty : 2001-03-30
- Definition of Underpayment : 2001-03-30
- Fraud Penalty : 2001-03-30
- Intent v. No Intent to Defraud : 2001-01-26
- Fraud Penalty : 2001-01-26
- Burden of Proof Taxpayer v. Commissioner : 2001-01-26
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