§ 6684. Assessable penalties with respect to liability for tax under chapter 42
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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 - |
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(1) |
such person has theretofore been liable for tax under such chapter, or |
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(2) |
such act or failure to act is both willful and flagrant, |
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then such person shall be liable for a penalty equal to the amount of such tax. |
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