Editor's Note:
Pub. L. 111-325, Sec. 501(a), struck Sec. 6697, effective for taxable years beginning after Dec. 22, 2010.
I.R.C. § 6697(a) Civil Penalty —
In addition to any other penalty provided by law, any regulated investment company
whose tax liability for any taxable year is deemed to be increased pursuant to section
860(c)(1)(A) shall pay a penalty in an amount equal to the amount of the interest (for which
such company is liable) which is attributable solely to such increase.
I.R.C. § 6697(b) 50-Percent Limitation —
The penalty payable under this section with respect to any determination shall not
exceed one-half of the amount of the deduction allowed by section 860(a) for such taxable year.
I.R.C. § 6697(c) Deficiency Procedures Not To Apply —
Subchapter B of chapter 63 (relating to deficiency procedure for income, estate,
gift, and certain excise taxes) shall not apply in respect of the assessment or collection
of any penalty imposed by subsection (a).
(Added by Pub. L. 94-455, title XVI, 1601(b)(1), Oct. 4, 1976, 90 Stat. 1745, and amended Pub. L. 95-600, title III, 362(b), Nov.
6, 1978, 92 Stat. 2851; Pub. L. 99-514, title VI, 667(a), Oct. 22, 1986, 100 Stat. 2305; and struck by Pub. L. 111-325, Sec. 501(a), Dec. 22, 2010, 124 Stat. 3537.)
BACKGROUND NOTES
AMENDMENTS
2010--Pub. L. 111-325, Sec. 501(a), struck Sec. 6697.
1986--Pub. L. 99-514 substituted
“regulated investment companies” for “real estate investment entities"
in section catchline.
Subsec. (a). Pub. L. 99-514 amended subsec. (a) generally. Prior to amendment, subsec. (a) read as follows:
“In addition to any other penalty provided by law, any qualified investment entity
(as defined in section 860(b)) whose tax liability for any taxable year is deemed
to be increased pursuant to section 860(c)(1)(A)
(relating to interest and additions to tax determined with respect to the amount of
the deduction for deficiency dividends allowed) shall pay a penalty in an amount equal
to the amount of interest (for which such entity is liable) which is attributable
solely to such increase.”
1978--Pub. L. 95-600 substituted “qualified investment entities” for
“real estate investment trusts” in section catchline.
Subsec. (a). Pub. L. 95-600 substituted
“qualified investment entity (as defined in section 860(b))” for “real estate investment
trust”, “section 860(c)(1)(A)” for “section 859(b)(2)(A)”, and “(for which such entity
is liable) which” for “for which such trust is liable that”.
Subsec. (b). Pub. L. 95-600 substituted
“section 860(a)” for “section 859(a)”.
Subsec. (c). Pub. L. 95-600 reenacted subsec. (c) without change.
EFFECTIVE DATE OF REPEAL
Repeal by Pub. L. 111-325, Sec. 501(a), effective for taxable years beginning after the date of the enactment of this Act
[Enacted: Dec. 22, 2010].
EFFECTIVE DATE OF 1986 AMENDMENT
Amendment by Pub. L. 99-514 applicable to taxable years beginning after Dec. 31, 1986, see section 669 of Pub. L. 99-514, set out as a note under section 856 of this title.
EFFECTIVE DATE OF 1978 AMENDMENT
Amendment by Pub. L. 95-600 applicable with respect to determinations (as defined in section 860(e) of this title)
after Nov. 6, 1978, see section 362(e) of Pub. L. 95-600, set out as an Effective Date note under section 860 of this title.
