Fabio
76b8ec33a7
Ingested titles 12–51 and 54 from OLRC USLM XML @119-100 (the whole Code now, uniform edition; Title 53 is reserved/empty). LegalText 11,221 -> 59,740; repo total 105,704 records. Deterministic (byte-identical rerun, verified on Title 42's 8,356 sections); make check green. make legal-us-code default now covers every title. Co-Authored-By: Claude Opus 4.8 <noreply@anthropic.com>
46 lines
2.2 KiB
Markdown
46 lines
2.2 KiB
Markdown
---
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type: "LegalText"
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title: "26 U.S.C. § 6663"
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description: "Imposition of fraud penalty"
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jurisdiction: "us"
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corpus: "united_states_code"
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kind: "code_section"
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title_number: 26
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title_name: "INTERNAL REVENUE CODE"
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chapter_number: "68"
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chapter_name: "ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES"
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section: "6663"
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citation: "26 U.S.C. § 6663"
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status: "current"
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release_point: "119-100"
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release_date: "2026-06-26"
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source: "official"
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source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
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source_identifier: "/us/usc/t26/s6663"
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source_file: "data/legal/raw/us/code/title-26/usc26.xml"
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source_hash: "3494eb39e08b41aacd6c0a2b5f1087f4685665a140d753a9e2cec9d2cd2962b5"
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raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
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text_hash: "988d0de14f183e5a204632c52527e9ffb1def4f11d06302defcd631e511c65bf"
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retrieved_at: "2026-07-04"
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confidence: "official"
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tags: ["legal", "us-code"]
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---
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# 26 U.S.C. § 6663 - Imposition of fraud penalty
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## Text
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(a) Imposition of penalty If any part of any underpayment of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 75 percent of the portion of the underpayment which is attributable to fraud.
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(b) Determination of portion attributable to fraud If the Secretary establishes that any portion of an underpayment is attributable to fraud, the entire underpayment shall be treated as attributable to fraud, except with respect to any portion of the underpayment which the taxpayer establishes (by a preponderance of the evidence) is not attributable to fraud.
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(c) Special rule for joint returns In the case of a joint return, this section shall not apply with respect to a spouse unless some part of the underpayment is due to the fraud of such spouse.
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(Added Pub. L. 101–239, title VII, § 7721(a), Dec. 19, 1989, 103 Stat. 2397.)
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## Notes
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Statutory Notes and Related Subsidiaries
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Effective DateSection applicable to returns the due date for which (determined without regard to extensions) is after Dec. 31, 1989, see section 7721(d) of Pub. L. 101–239, set out as an Effective Date of 1989 Amendment note under section 461 of this title.
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