§ 6712. Failure to disclose treaty-based return positions
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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. |
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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. |
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(c) |
Penalty in addition to other penalties |
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The penalty imposed by this section shall be in addition to any other penalty imposed by law. |
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