26 U.S. Code § 6701 - Penalties for aiding and abetting understatement of tax liability
Except as provided in paragraph (2), the amount of the penalty imposed by subsection (a) shall be $1,000.
If any person is subject to a penalty under subsection (a) with respect to any document relating to any taxpayer for any taxable period (or where there is no taxable period, any taxable event), such person shall not be subject to a penalty under subsection (a) with respect to any other document relating to such taxpayer for such taxable period (or event).
For purposes of paragraph (1), the term “subordinate” means any other person (whether or not a director, officer, employee, or agent of the taxpayer involved) over whose activities the person has direction, supervision, or control.
For purposes of subsection (a)(1), a person furnishing typing, reproducing, or other mechanical assistance with respect to a document shall not be treated as having aided or assisted in the preparation of such document by reason of such assistance.
Except as provided by paragraphs (2) and (3), the penalty imposed by this section shall be in addition to any other penalty provided by law.
No penalty shall be assessed under subsection (a) or (b) of section 6694 on any person with respect to any document for which a penalty is assessed on such person under subsection (a).
No penalty shall be assessed under section 6700 on any person with respect to any document for which a penalty is assessed on such person under subsection (a).
1989—Subsec. (a)(1). Pub. L. 101–239, § 7735(a)(1), struck out “in connection with any matter arising under the internal revenue laws” after “other document”.
Subsec. (a)(2). Pub. L. 101–239, § 7735(a)(2), inserted “(or has reason to believe)” after “who knows”.
Subsec. (a)(3). Pub. L. 101–239, § 7735(a)(3), substituted “would result” for “will result”.
Subsec. (f)(1). Pub. L. 101–239, § 7735(b)(2), substituted “paragraphs (2) and (3)” for “paragraph (2)”.
Subsec. (f)(3). Pub. L. 101–239, § 7735(b)(1), added par. (3).
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.
- Penalty Amount : 2018-02-02
- Penalty Amount : 2017-10-20
- Willful Understatement of Liability : 2015-05-08
- Promoting Abusive Tax Shelters : 2012-08-31
- Collection Due Process - Levy : 2012-03-16
- Rules Applicable to Penalties Under Section 6700, 6701, and 6702 See Also 6700, 6701, 6702 : 2012-03-16
- Penalty Amount : 2010-09-10
- Value of Contribution : 2010-06-04
- Action for Recovery of Erroneous Refunds : 2009-06-05
- Fraud Penalty : 2009-06-05
- Person Liable : 2009-06-05
- Frivolous Income Tax Return : 2001-01-12
- Person Liable : 2001-01-12
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