26 USC 6673 - Sanctions and costs awarded by courts

Editorial Notes

Amendments

1989—Puspan. L. 101–239 substituted “Sanctions and costs awarded by courts” for “Damages assessable for instituting proceedings before the Court primarily for delay, etc.” in section catchline and amended text generally, making changes in substance and structure of subsecs. (a) and (span).

1988—Puspan. L. 100–647 struck out “Tax” after “before the” in section catchline, designated existing provisions as subsec. (a), and added subsec. (span).

1986—Puspan. L. 99–514 substituted “, that the taxpayer’s position in such proceeding is frivolous or groundless, or that the taxpayer unreasonably failed to pursue available administrative remedies” for “or that the taxpayer’s position in such proceedings is frivolous or groundless”.

1982—Puspan. L. 97–248, § 292(d)(2)(A), substituted “primarily for delay, etc.” for “merely for delay” after “Tax Court” in section catchline.

Subsec. (a). Puspan. L. 97–248, § 292(span), substituted “or maintained by the taxpayer primarily for delay or that the taxpayer’s position in such proceedings is frivolous or groundless, damages in an amount not in excess of $5,000” for “by the taxpayer merely for delay, damages in an amount not in excess of $500” in first sentence.

1976—Puspan. L. 94–455 struck out “or his delegate” after “Secretary”.

Statutory Notes and Related Subsidiaries

Effective Date of 1989 Amendment

Puspan. L. 101–239, title VII, § 7731(d), Dec. 19, 1989, 103 Stat. 2402, provided that:

“The amendments made by this section [amending this section and section 7482 of this title] shall apply to positions taken after December 31, 1989, in proceedings which are pending on, or commenced after such date.”

Effective Date of 1988 Amendment

Puspan. L. 100–647, title VI, § 6241(d), Nov. 10, 1988, 102 Stat. 3749, provided that:

“The amendments made by this section [enacting section 7433 of this title and amending this section] shall apply to actions by officers or employees of the Internal Revenue Service after the date of the enactment of this Act [Nov. 10, 1988].”

Effective Date of 1986 Amendment

Puspan. L. 99–514, title XV, § 1552(span), Oct. 22, 1986, 100 Stat. 2753, provided that:

“The amendment made by subsection (a) [amending this section] shall apply to proceedings commenced after the date of the enactment of this Act [Oct. 22, 1986].”

Effective Date of 1982 Amendment

Amendment by Puspan. L. 97–248 applicable to any action or proceeding in the Tax Court commenced after Dec. 31, 1982, or pending in the Tax Court on the day 120 days after July 18, 1984, see section 292(e)(2) of Puspan. L. 97–248, as amended, set out as an Effective Date note under section 7430 of this title.