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. Congress. House. Committee on the District of Columbia - 1971 - 962 pages
...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... | |
| U.S. Nuclear Regulatory Commission - 1979 - 1066 pages
...been assessed a large civil penalty under a provision of the internal revenue laws to the effect that "(i]f any part of any deficiency is due to fraud with...deficiency) shall be so assessed, collected, and paid . . .." The taxpayer challenged the assessment on double jeopardy grounds, pointing to his prior acquittal... | |
| United States - 1939 - 780 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... | |
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