26 USC 6233 - Interest and penalties

U.S Code last checked for updates: Jan 19, 2025

§ 6233.

Interest and penalties

(a)

Interest and penalties determined from reviewed year

(1)

In general

Except to the extent provided in section 6226(c), in the case of a partnership adjustment for a reviewed year—

(A)

interest shall be computed under paragraph (2), and

(B)

the partnership shall be liable for any penalty, addition to tax, or additional amount as provided in paragraph (3).

(2)

Determination of amount of interest

(3)

Penalties

(b)

Interest and penalties with respect to adjustment year return

(1)

In general

In the case of any failure to pay an imputed underpayment on the date prescribed therefor, the partnership shall be liable—

(A)

for interest as determined under paragraph (2), and

(B)

for any penalty, addition to tax, or additional amount as determined under paragraph (3).

(2)

Interest

(3)

Penalties

Penalties, additions to tax, or additional amounts determined under this paragraph are the penalties, additions to tax, or additional amounts that would be determined—

(A)

by applying section 6651(a)(2) to such failure to pay, and

(B)

by treating the imputed underpayment as an underpayment of tax for purposes of part II of subchapter A of chapter 68.

(c)

Deposit to suspend interest

(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 633; amended Pub. L. 115–141, div. U, title II, § 206(i), Mar. 23, 2018, 132 Stat. 1180.)

cite as: 26 USC 6233