Taxable Years by this chapter, within the time prescribed by law or prescribed by the Commissioner in pursuance of law, unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the tax: 5 per centum if the failure is for not more than thirty days with an additional 5 per centum for each additional thirty days or fraction thereof during which such failure continues, not exceeding 25 per centum in the aggregate. The amount so added to any tax shall be collected at the same time and in the same manner and as a part of the tax unless the tax has been paid before the discovery of the neglect, in which case the amount so added shall be collected in the same manner as the tax. The amount added to the tax under this section shall be in lieu of the 25 per centum addition to the tax provided in section 3612 (d) (1). Sec. 291. (b) For minimum addition to the tax for failure of withholding agent to make and file return required by Part II of Subchapter D, see section 470 (c). Sec. 291, I. R. C., supra. amended by Sec. 172 (f) (4), R. A. of 1942, by adding "a" before first paragraph and by adding paragraph (b). Sec. 172 (g) of said Act makes amendment effective on Jan. 1, 1943, and applicable to all wages (as defined in Part II of Subchapter D) paid on or after said date. chapter, within the time prescribed chapter, within the time prescribed Sec. 292. Interest on deficiencies. Interest upon the amount determined as a deficiency shall be assessed at the same time as the deficiency, shall be paid upon notice and demand from the collector, and shall be collected as a part of the tax, at the rate of 6 per centum per annum from the date prescribed for the payment of the tax (or, if the tax is paid in installments, from the date prescribed for the payment of the first installment) to the date the deficiency is assessed, or, in the case of a waiver under section 272 (d), to the thirtieth day after the filing of such waiver or to the date the Sec. 292. Interest on deficiencies. Sec. 292. Interest on deficiencies. Interest upon the amount deterInterest upon the amount determined as a deficiency shall be as- mined as a deficiency shall be assessed at the same time as the de- sessed at the same time as the deficiency, shall be paid upon notice ficiency, shall be paid upon notice and demand from the collector, and and demand from the collector, and shall be collected as a part of the shall be collected as a part of the tax, at the rate of 6 per centum per tax, at the rate of 6 per centum per annum from the date prescribed annum from the date prescribed for the payment of the tax (or, if for the payment of the tax (or, if the tax is paid in installments, the tax is paid in installments, from the date prescribed for the from the date prescribed for the payment of the first installment) payment of the first installment) to the date the deficiency is as- to the date the deficiency is assessed, or, in the case of a waiver sessed, or, in the case of a waiver under section 272 (d), to the under section 272 (d), to the thirtieth day after the filing of thirtieth day after the filing of such waiver or to the date the such waiver or to the date the deficiency is assessed whichever is deficiency is assessed whichever is deficiency is assessed whichever is the earlier.* the earlier.* * Sec. 292, I. R. C., supra, was amended by Sec. 2, H. R. 3363, approved Nov. 1943, (1) by inserting at the beginning thereof the following: (a) General rule.-" and (2) by inserting at the end thereof the following new paragraph: (b) Deficiency resulting from relief under section 722. -If any part of a deficiency for a taxable year be the earlier.* ginning prior to January 1, 1942, is determined by the Commissioner to be attributable to the final determination of an application for relief or benefit under section 722 for any taxable year, no interest shall be assessed or paid with respect to such part of the deficiency. If any part of a deficiency for a taxable year beginning after December 31, 1941, is determined by the Commissioner chapter, within the time prescribed chapter, within the time prescribed by law or prescribed by the Com- by law or prescribed by the Commissioner in pursuance of law, un-missioner in pursuance of law, unless it is shown that such failure is less it is shown that such failure is due to reasonable cause and not due to reasonable cause and not due to willful neglect, there shall due to willful neglect, there shall be added to the tax: 5 per centum be added to the tax: 5 per centum if the failure is for not more than if the failure is for not more than thirty days with an additional 5 thirty days with an additional 5 per centum for each additional per centum for each additional thirty days or fraction thereof dur- thirty days or fraction thereof during which such failure continues, ing which such failure continues, not exceeding 25 per centum in the not exceeding 25 per centum in the aggregate. The amount so added aggregate. The amount so added to any tax shall be collected at the to any tax shall be collected at the same time and in the same manner same time and in the same manner and as a part of the tax unless the and as a part of the tax unless the tax has been paid before the dis- tax has been paid before the discovery of the neglect, in which case covery of the neglect, in which case the amount so added shall be col- the amount so added shall be collected in the same manner as the lected in the same manner as the tax. The amount added to the tax tax. The amount added to the tax under this section shall be in lieu under this section shall be in lieu of the 25 per centum addition to the tax provided in section 3612 (d) (1). of the 25 per centum addition to the tax provided in section 3612 (d) (1). Taxable Years Sec. 292. Interest on deficiencies. Sec. 292. Interest on deficiencies. Interest upon the amount deter- Interest upon the amount determined as a deficiency shall be as- mined as a deficiency shall be assessed at the same time as the de- sessed at the same time as the deficiency, shall be paid upon notice ficiency, shall be paid upon notice and demand from the collector, and and demand from the collector, and shall be collected as a part of the shall be collected as a part of the tax, at the rate of 6 per centum per tax, at the rate of 6 per centum per annum from the date prescribed annum from the date prescribed for the payment of the tax (or, if for the payment of the tax (or, if the tax is paid in installments, the tax is paid in installments, from from the date prescribed for the the date prescribed for the paypayment of the first installment) ment of the first installment) to the to the date the deficiency is as- date the deficiency is assessed, or, sessed, or, in the case of a waiver in the case of a waiver under secunder section 272 (d), to the tion 272 (d), to the thirtieth day thirtieth day after the filing of after the filing of such waiver or such waiver or to the date the to the date the deficiency is asdeficiency is assessed whichever is sessed whichever is the earlier. the earlier.* to be attributable to the final determination of an application for relief or benefit under section 722 for any taxable year (excluding any portion of a deficiency of excess profits taxes constituting a deficiency by reason of deferment of tax under section 710 (a) (5), and excluding, in case the taxpayer has availed itself of the benefits of section 710 (a) (5), such portion of a de Sec. 292. Interest on deficiencies. See p. 378, Eighth Edition. ficiency under Chapter 1 as may be determined by the Commissioner to exceed any refund or credit of excess profits tax arising from the operation of section 722), no interest shall be assessed or paid with respect to such part of the deficiency for any period prior to one year after the filing of such application, or September 16, 1945, whichever is the later. Taxable Years Sec. 293. Additions to the tax in case of deficiency. Sec. 293. (a) Negligence.-If any part of any deficiency is due to negligence, or intentional disregard of rules and regulations but without intent to defraud, 5 per centum of the total amount of the deficiency (in addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency, except that the provisions of section 272 (i), relating to the prorating of a deficiency, and of section 292, relating to interest on deficiencies, shall not be applicable. Sec. 293. (b) Fraud.—If any part of any deficiency is due to fraud with intent to evade tax, then 50 per centum of the total amount of the deficiency (in addition to such deficiency) shall be so assessed, collected, and paid, in lieu of the 50 per centum addition to the tax provided in section 3612 (d) (2). Sec. 294. Additions to the tax in case of nonpayment. Sec. 294. (a) Tax shown on return. Taxable Years Sec. 293. Additions to the tax in case of deficiency. Taxable Years Sec. 293. Additions to the tax in case of deficiency. Sec. 293. (a) Negligence.-If Sec. 293. (a) Negligence. If any part of any deficiency is due any part of any deficiency is due to negligence, or intentional dis- to negligence, or intentional disregard of rules and regulations but regard of rules and regulations but without intent to defraud, 5 per without intent to defraud, 5 per centum of the total amount of the centum of the total amount of the deficiency (in addition to such de-deficiency (in addition to such deficiency) shall be assessed, collected, ficiency) shall be assessed, collected, and paid in the same manner as if and paid in the same manner as if it were a deficiency, except that the it were a deficiency, except that the provisions of section 272 (i), re- provisions of section 272 (i), relating to the prorating of a defi- lating to the prorating of a deficiency, and of section 292, relating ciency, and of section 292, relating to interest on deficiencies, shall not to interest on deficiencies, shall not be applicable. be applicable. Sec. 293. (b) Fraud.-If any part of any deficiency is due to fraud with intent to evade tax, then 50 per centum of the total amount of the deficiency (in addition to such deficiency) shall be so assessed, collected, and paid, in lieu of the 50 per centum addition to the tax provided in section 3612 (d) (2). Sec. 294. Additions to the tax in case of nonpayment. Sec. 294. (a) Tax shown on return. Sec. 294. (a) (1) General rule.— Sec. 294. (a) (1) General rule.— Where the amount determined by Where the amount determined by the taxpayer as the tax imposed by the taxpayer as the tax imposed by this chapter, or any installment this chapter, or any installment thereof, or any part of such amount thereof, or any part of such amount or installment, is not paid on or or installment, is not paid on or before the date prescribed for its before the date prescribed for its payment, there shall be collected payment, there shall be collected as a part of the tax, interest upon as a part of the tax, interest upon such unpaid amount at the rate of such unpaid amount at the rate of 6 per centum per annum from the 6 per centum per annum from the date prescribed for its payment date prescribed for its payment until it is paid. until it is paid. Sec. 293. (b) Fraud.-If any part of any deficiency is due to fraud with intent to evade tax, then 50 per centum of the total amount of the deficiency (in addition to such deficiency) shall be so assessed, collected, and paid, in lieu of the 50 per centum addition to the tax provided in section 3612 (d) (2). Sec. 294. Additions to the tax in case of nonpayment. Sec. 294. (a) Tax shown on return. Sec. 294. (a) (1) General rule.Where the amount determined by the taxpayer as the tax imposed by this chapter, or any installment thereof, or any part of such amount or installment, is not paid on or before the date prescribed for its payment, there shall be collected as a part of the tax, interest upon such unpaid amount at the rate of 6 per centum per annum from the date prescribed for its payment until it is paid. Sec. 294. (a) (2) If extension Sec. 294. (a) (2) If extension Sec. 294. (a) (2) If extension granted. Where an extension of granted. Where an extension of granted. Where an extension of time for payment of the amount so time for payment of the amount so time for payment of the amount so determined as the tax by the tax-determined as the tax by the tax- determined as the tax by the taxpayer, or any installment thereof, payer, or any installment thereof, payer, or any installment thereof, has been granted, and the amount has been granted, and the amount has been granted, and the amount the time for payment of which has the time for payment of which has the time for payment of which has been extended, and the interest been extended, and the interest been extended, and the interest thereon determined under section thereon determined under section thereon determined under section 295, is not paid in full prior to the expiration of the period of the extension, then, in lieu of the interest provided for in paragraph (1) of this subsection, interest at the rate of 6 per centum per annum shall be 295, is not paid in full prior to the 295, is not paid in full prior to the expiration of the period of the extension, then, in lieu of the interest provided for in paragraph (1) of this subsection, interest at the rate of 6 per centum per annum shall be Taxable Years Sec. 293. Additions to the tax in case of deficiency. Taxable Years Sec. 293. Additions to the tax in case of deficiency. Sec. 293. (a) Negligence.-If Sec. 293. (a) Negligence.-If any part of any deficiency is due any part of any deficiency is due to negligence, or intentional dis- to negligence, or intentional disregard of rules and regulations but regard of rules and regulations but without intent to defraud, 5 per without intent to defraud, 5 per centum of the total amount of the centum of the total amount of the deficiency (in addition to such de- deficiency (in addition to such deficiency) shall be assessed, collected, ficiency) shall be assessed, collected, and paid in the same manner as if and paid in the same manner as if it were a deficiency, except that the it were a deficiency, except that the provisions of section 272 (i), re- provisions of section 272 (i), relating to the prorating of a defi-lating to the prorating of a deficiency, and of section 292, relating ciency, and of section 292, relating to interest on deficiencies, shall not to interest on deficiencies, shall not be applicable. be applicable. Sec. 293. (b) Fraud.—If any Sec. 293. (b) Fraud. If any part of any deficiency is due to part of any deficiency is due to fraud with intent to evade tax, fraud with intent to evade tax, then 50 per centum of the total then 50 per centum of the total amount of the deficiency (in addi- amount of the deficiency (in addition to such deficiency) shall be so assessed, collected, and paid, in lieu of the 50 per centum addition to the tax provided in section 3612 (d) (2). Sec. 294. Additions to the tax in case of nonpayment. Sec. 294. (a) Tax shown on return. tion to such deficiency) shall be so Sec. 294. Additions to the tax Sec. 294. (a) Tax shown on return. Sec. 294. (a) (1) General rule.— Sec. 294. (a) (1) General rule.— Where the amount determined by Where the amount determined by the taxpayer as the tax imposed by the taxpayer as the tax imposed by this chapter, or any installment this chapter, or any installment thereof, or any part of such amount thereof, or any part of such amount or installment, is not paid on or or installment, is not paid on or before the date prescribed for its before the date prescribed for its payment, there shall be collected payment, there shall be collected as a part of the tax, interest upon as a part of the tax, interest upon such unpaid amount at the rate of such unpaid amount at the rate of 6 per centum per annum from the 6 per centum per annum from the date prescribed for its payment date prescribed for its payment until it is paid. until it is paid. Taxable Years Sec. 293. Additions to the tax in case of deficiency. Sec. 293. (a) Negligence. See p. 378, Eighth Edition. Sec. 293. (b) Fraud. See p. 378, Eighth Edition. Sec. 294. Additions to the tax in case of nonpayment. Sec. 294. (a) Tax shown on return. Sec. 294. (a) (1) General rule. Sec. 294. (a) (2) If extension See p. 380, Eighth Edition. Sec. 294. (a) (2) If extension Sec. 294. (a) (2) If extension Taxable Years Taxable Years Taxable Years collected on such unpaid amount collected on such unpaid amount collected on such unpaid amount from the date of the expiration of from the date of the expiration of from the date of the expiration of the period of the extension until it the period of the extension until it the period of the extension until it is paid. is paid. is paid. Sec. 294. (a) (3) Failure to file declaration of estimated tax.-In the case of a failure to make and file a declaration of estimated tax within the time prescribed, there shall be added to the tax an amount equal to 10 per centum of the tax. Sec. 294. (a) (4) Failure to pay installment of estimated tax.-In the case of the failure to pay an installment of the estimated tax within the time prescribed, there shall be added to the tax $2.50 or 22 per centum of the tax, whichever is the greater, for each installment with respect to which such failure occurs. Sec. 294. (a) (5) Substantial underestimate of estimated tax.If 80 per centum of the tax (determined without regard to the credits under sections 32, 35, and 466 (e)), in the case of individuals other than farmers exercising an election under section 60 (a) or 663 per centum of such tax so determined in the case of such farmers, exceeds the estimated tax (increased by such credits), there shall be added to the tax an amount equal to such excess, or equal to 6 per centum of the amount by which such tax so determined exceeds the estimated tax so increased, whichever is the lesser. This paragraph shall not apply to the taxable year in which falls the death of the taxpayer. Sec. 294 (a), I. R. C., amended by Sec. 5 (b), Current Tax Payment Act of 1943, by adding paragraphs (3), (4) and (5) shown in italics. Sec. 5 (f) of said Act makes amendment effective with respect to taxable years beginning after Dec. 31, 1942, except that Sec. 294 (a) (5), I. R. C., shall not be applicable to taxable year beginning in 1943 in the case of an individual not required to make a declaration under Sec. 58, I. R. C., for such year. Sec. 294. (b) Deficiency.-Where Sec. 294. (b) Deficiency.-Where a deficiency, or any interest or ad- a deficiency, or any interest or additional amounts assessed in con- ditional amounts assessed in connection therewith under section 292, nection therewith under section 292, or under section 293, or any addi- or under section 293, or any addition to the tax in case of delin- tion to the tax in case of delinquency provided for in section 291, quency provided for in section 291, is not paid in full within ten days is not paid in full within ten days Sec. 294. (b) Deficiency.-Where a deficiency, or any interest or additional amounts assessed in connection therewith under section 292, or under section 293, or any addition to the tax in case of delinquency provided for in section 291, is not paid in full within ten days |