# 26 U.S.C. § 6665: Applicable rules

Source: OLRC release point 119-134 <https://uscode.house.gov/us/usc/119-134/t26/s6665>. Cite pinpoints as 26 U.S.C. § 6665(a)(1).

## § 6665(a) Additions treated as tax

Except as otherwise provided in this title—

**§ 6665(a)(1)** the additions to the tax, additional amounts, and penalties provided by this chapter shall be paid upon notice and demand and shall be assessed, collected, and paid in the same manner as taxes; and

**§ 6665(a)(2)** any reference in this title to “tax” imposed by this title shall be deemed also to refer to the additions to the tax, additional amounts, and penalties provided by this chapter.

## § 6665(b) Procedure for assessing certain additions to tax

For purposes of subchapter B of chapter 63 (relating to deficiency procedures for income, estate, gift, and certain excise taxes), subsection (a) shall not apply to any addition to tax under section 6651, 6654, or 6655; except that it shall apply—

**§ 6665(b)(1)** in the case of an addition described in section 6651, to that portion of such addition which is attributable to a deficiency in tax described in section 6211; or

**§ 6665(b)(2)** to an addition described in section 6654 or 6655, if no return is filed for the taxable year.

## Leading cases

- [Mendes v. Commissioner, 121 T.C. 308 (2003)](https://www.courtlistener.com/opinion/4696857/mendes-v-commr/)
- [Liberty University v. Geithner, 671 F.3d 391 (4th Cir. 2011)](https://www.courtlistener.com/opinion/613324/liberty-university-v-timothy-geithner/)
- [Higbee v. Commissioner, 116 T.C. 438 (2001)](https://www.courtlistener.com/opinion/4696566/higbee-v-commissioner-of-internal-revenue/)

## Connections

Cites: § 6211 Definition of a deficiency; § 6651 Failure to file tax return or to pay tax; § 6654 Failure by individual to pay estimated income tax

Cited by: § 5114 Drawback; § 5684 Penalties relating to the payment and collection of liquor taxes; § 5761 Civil penalties

## Amendments

- 1989-12-19: [Pub. L. 101-239](/26/act/101-239.md), 103 Stat. 2399
