26 U.S. Code § 6725 - Failure to report information under
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(a) In general
In the case of each failure described in subsection (b) by any person with respect to a vessel or facility, such person shall pay a penalty of $10,000 in addition to the tax (if any).
(b) Failures subject to penalty
For purposes of subsection (a), the failures described in this subsection are—
(1) any failure to make a report under section 4101 (d) on or before the date prescribed therefor, and