# 26 U.S.C. § 6684: Assessable penalties with respect to liability for tax under chapter 42

Source: OLRC release point 119-134 <https://uscode.house.gov/us/usc/119-134/t26/s6684>. Cite pinpoints as 26 U.S.C. § 6684(a)(1).

If any person becomes liable for tax under any section of chapter 42 (relating to private foundations and certain other tax-exempt organizations) by reason of any act or failure to act which is not due to reasonable cause and either—

## § 6684(1)

such person has theretofore been liable for tax under such chapter, or

## § 6684(2)

such act or failure to act is both willful and flagrant,

then such person shall be liable for a penalty equal to the amount of such tax.

## Regulations

- [Treas. Reg. § 301.6684-1](/26/reg/301.6684-1.md): Assessable penalties with respect to liability for tax under chapter 42. (interprets § 6684)

## Leading cases

- [Adams v. Commissioner, 70 T.C. 373 (1978)](https://www.courtlistener.com/opinion/4704786/adams-v-commissioner/)
- [Larchmont Foundation, Inc. v. Commissioner, 72 T.C. 131 (1979)](https://www.courtlistener.com/opinion/4704971/larchmont-foundation-inc-v-commissioner/)
- [Moody v. Commissioner, T.C. Memo. 1995-195](https://www.courtlistener.com/opinion/4827452/moody-v-commissioner/)

## Connections

Cites: none

Cited by: § 4948 Application of taxes and denial of exemption with respect to certain foreign organizations

## Amendments

- 1969-12-30: [Pub. L. 91-172](/26/act/91-172.md), 83 Stat. 519
- 1987-12-22: [Pub. L. 100-203](/26/act/100-203.md), 101 Stat. 1330