
From the U.S. Code Online via GPO Access
[wais.access.gpo.gov]
[Laws in effect as of January 2, 2001]
[Document not affected by Public Laws enacted between
  January 2, 2001 and January 28, 2002]
[CITE: 26USC6712]

 
                     TITLE 26--INTERNAL REVENUE CODE
 
                Subtitle F--Procedure and Administration
 
  CHAPTER 68--ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE 
                                PENALTIES
 
                   Subchapter B--Assessable Penalties
 
                       PART I--GENERAL PROVISIONS
 
Sec. 6712. Failure to disclose treaty-based return positions


(a) General rule

    If a taxpayer fails to meet the requirements of section 6114, there 
is hereby imposed a penalty equal to $1,000 ($10,000 in the case of a C 
corporation) on each such failure.

(b) Authority to waive

    The Secretary may waive all or any part of the penalty provided by 
this section on a showing by the taxpayer that there was reasonable 
cause for the failure and that the taxpayer acted in good faith.

(c) Penalty in addition to other penalties

    The penalty imposed by this section shall be in addition to any 
other penalty imposed by law.

(Added Pub. L. 100-647, title I, Sec. 1012(aa)(5)(B), Nov. 10, 1988, 102 
Stat. 3532.)

                          Codification

    Another section 6712 was renumbered section 6713 of this title.


                             Effective Date

    Section applicable to taxable periods the due date for filing 
returns for which (without extension) occurs after Dec. 31, 1988, see 
section 1012(aa)(5)(D) of Pub. L. 100-647, set out as a note under 
section 6114 of this title.
