If any part of any deficiency is due to negligence, or intentional disregard of rules and regulations but without intent to defraud. 5 per centum of the total amount of the deficiency (In addition to such deficiency) shall be assessed, collected, and... Reports of the Tax Court of the United States - Page 699by United States. Tax Court - 1963Full view - About this book
| United States, Walter Elbert Barton - 1944 - 1286 pages
...due to negligence, or intentional disregard of rules and regulations but without intent to defraud, 5 per centum of the total amount of the deficiency (in addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency, except that the provisions... | |
| United States. Congress. Internal Revenue Taxation Joint Committee - 1945 - 350 pages
...due to negligence, or intentional disregard of rules and regulations but without intent to defraud, 5 per centum of the 'total amount of the deficiency (in addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency, except that the provisions... | |
| United States. Congress. Joint Committee on Internal Revenue Taxation - 1946 - 428 pages
...due to negligence, or intentional disregard of rules and regulations but without intent to defraud, 5 per centum of the total amount of the deficiency (in addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency, except that the provisions... | |
| United States. Congress. Senate. Committee on the District of Columbia - 1947 - 1798 pages
...to negligence, or intentional (ffsregard of rules and regulations but without intent to defraud, 5 per centum of the total amount of the deficiency (in addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency. SEC. 4. ADDITIONS TO THE... | |
| United States. Congress. Senate. Committee on the District of Columbia - 1947 - 1136 pages
...due to negligence, or intentional disregard of rules and regulations but without intent to defraud, 5 per centum of the total amount of the deficiency (in addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency. (b) FRAUD. — If any... | |
| United States. Bureau of Employment Security - 1941 - 1182 pages
...deficiency in payment of the employer's contribution is due to negligence" (or fraud) a specified percentum of the total amount of the deficiency, in addition to such deficiency, shall be assessed, collected and paid "in the same manner as if it were a deficiency." Since by subdivision... | |
| United States, Walter Elbert Barton - 1950 - 1126 pages
...section 1021, relating to interest on deficiencies, shall not be applicable. Sec. 1O19. (b) (Frand).—If any part of any deficiency is due to fraud with intent...deficiency) shall be so assessed, collected, and paid, in lieu of the 50 per' centum addition to the tax provided in section 3612 (d) (2). Sec. 1019, IRC, supra,... | |
| United States. Congress. House. Committee on Ways and Means - 1952 - 1142 pages
...attempted to evade or defeat. The Tax Court again, as to the civil-fraud penalty, that statute reads if any part of any deficiency is due to fraud with intent to evade tax, then the 50percent shall be added on. So it does not require that all of the case be fraudulent either to... | |
| New York (State) - 1953 - 1468 pages
...collected and paid as part of the payment required to be made by the employer to the fund. 4. Fraud. If any part of any deficiency is due to fraud with intent to avoid payment of contributions to the fund, fifty per centum of the total amount of the deficiency,... | |
| United States. Internal Revenue Service - 1956 - 1348 pages
...intended to evade tax by fraudulent acts. Section 239 (b) of the Internal Revenue Code of 1939 provides: "If any part of any deficiency is due to fraud with...deficiency) shall be so assessed, collected, and paid, in lieu of the 50 per centum addition to the tax provided in section 3612 ection 39.271-1 (a) of Regulations... | |
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