Title 26Internal Revenue CodeRelease 119-73not60

§6684 Assessable Penalties with Respect to Liability for Tax Under Chapter 42

Title 26 › Subtitle Subtitle F— Procedure and Administration › Chapter 68— ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES › Subchapter B— Assessable Penalties › Part I— GENERAL PROVISIONS › § 6684

Last updated Apr 5, 2026|Official source

Summary

Imposes an extra penalty on anyone who becomes responsible for a tax under the rules for private foundations because of an act or failure to act that was not for a good reason. The penalty applies if that person already had a tax liability under those rules before, or if the act or omission was both intentional and clearly serious.

Full Legal Text

Title 26, §6684

Internal Revenue Code — Source: USLM XML via OLRC

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—
(1)such person has theretofore been liable for tax under such chapter, or
(2)such act or failure to act is both willful and flagrant,

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Amendments

1987—Pub. L. 100–203 inserted “and certain other tax-exempt organizations” after “private foundations” in parenthetical.

Statutory Notes and Related Subsidiaries

Effective Date

of 1987 AmendmentAmendment by Pub. L. 100–203 applicable to taxable years beginning after Dec. 22, 1987, see section 10712(d) of Pub. L. 100–203, set out as an

Effective Date

note under section 4955 of this title.

Effective Date

Section effective Jan. 1, 1970, see section 101(k)(1) of Pub. L. 91–172, set out as a note under section 4940 of this title.

Reference

Citations & Metadata

Citation

26 U.S.C. § 6684

Title 26Internal Revenue Code

Last Updated

Apr 5, 2026

Release point: 119-73not60