Final rules 1
(a) Computation of penalty included in notice The Secretary shall include with each notice of penalty under this title information with respect to the name of the penalty, the section of this title under which the penalty is imposed, and a computation of the penalty.
(b) Approval of assessment
Cases: Kroner v. Commissioner, 48 F.4th 1272 (11th Cir. 2022); PBBM-Rose Hill, Ltd. v. Commissioner, 900 F.3d 193 (5th Cir. 2018)
Cited by 3
(1) In general No penalty under this title shall be assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the individual making such determination or such higher level official as the Secretary may designate.
(2) Exceptions Paragraph (1) shall not apply to—
Cited by 1
(A) any addition to tax under section 6651, 6654, 6655, or 6662 (but only with respect to an addition to tax by reason of paragraph (9) or (10) of subsection (b) thereof); or
Amended 2020, 2022
- 2022 Pub. L. 117-328 Pub. L. 117–328 substituted “paragraph (9) or (10) of subsection (b)” for “subsection (b)(9)”.
- 2020 Pub. L. 116-260 Pub. L. 116–260 substituted “6655, or 6662 (but only with respect to an addition to tax by reason of subsection (b)(9) thereof)” for “or 6655”.
(c) Penalties For purposes of this section, the term “penalty” includes any addition to tax or any additional amount.