 | United States. Tax Court - 1956 - 1226 pages
...proceedings, under the provisions of section 293 (b) . The respondent has the burden of proving that part of any deficiency is due to fraud with intent to evade tax, and the evidence necessary to establish fraud must be clear and convincing. Snell Isle, Inc. v.... | |
 | United States. Tax Court - 1984 - 1120 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) If any part of... | |
 | United States. Congress. House. Committee on the District of Columbia - 1971 - 966 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... | |
 | United States. Congress. House. Committee on the District of Columbia - 1878 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... | |
 | 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. Tax Court - 1984 - 1122 pages
...deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency * (bl If any part of any deficiency is due to fraud with...deficiency) shall be so assessed, collected, and paid * * * ; (879) 887 ments made by the Commissioner. The taxpayers filed a petition disputing the "deficiencies"... | |
 | 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... | |
 | United States. Congress. Senate. Committee on the District of Columbia - 1966 - 1786 pages
...deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency. "(f) If any part of any deficiency is due to fraud with...deficiency) shall be so assessed, collected, and paid. "(g) Where a deficiency, or any interest or additional amounts assessed in connection therewith under... | |
| |
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... 
