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26 U.S.C. § 6673 — Sanctions and costs awarded by courts
Federal law — U.S. Code and appendices · legal_authorities
**(a) Tax court proceedings**
(1) **Procedures instituted primarily for delay, etc.** — Whenever it appears to the Tax Court that—
(A) proceedings before it have been instituted or maintained by the taxpayer primarily for delay,
(B) the taxpayer’s position in such proceeding is frivolous or groundless, or
(C) the taxpayer unreasonably failed to pursue available administrative remedies,
the Tax Court, in its decision, may require the taxpayer to pay to the United States a penalty not in excess of $25,000.
(2) **Counsel’s liability for excessive costs** — Whenever it appears to the Tax Court that any attorney or other person admitted to practice before the Tax Court has multiplied the proceedings in any case unreasonably and vexatiously, the Tax Court may require—
(A) that such attorney or other person pay personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct, or
(B) if such attorney is appearing on behalf of the Commissioner of Internal Revenue, that the United States pay such excess costs, expenses, and attorneys’ fees in the same manner as such an award by a district court.
**(b) Proceedings in other courts**
(1) **Claims under section 7433** — Whenever it appears to the court that the taxpayer’s position in the proceedings before the court instituted or maintained by such taxpayer under section 7433 is frivolous or groundless, the court may require the taxpayer to pay to the United States a penalty not in excess of $10,000.
(2) **Collection of sanctions and costs** — In any civil proceeding before any court (other than the Tax Court) which is brought by or against the United States in connection with the determination, collection, or refund of any tax, interest, or penalty under this title, any mon
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Stable record: federal_law:legal_authorities:record_usc_3ee4fe8b50199ded3da65b44
Source file: Laws/federal/codes/united-states-code/title-26/section-6673-sanctions-and-costs-awarded-by-courts--af7504f05f.md
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Source location: Title 26, Chapter 68, § 6673; chapter-068-additions-to-the-tax-additional-amounts-and-assessable-penalties.md
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**(a) Tax court proceedings**
(1) **Procedures instituted primarily for delay, etc.** — Whenever it appears to the Tax Court that—
(A) proceedings before it have been instituted or maintained by the taxpayer primarily for delay,
(B) the taxpayer’s position in such proceeding is frivolous or groundless, or
(C) the taxpayer unreasonably failed to pursue available administrative remedies,
the Tax Court, in its decision, may require the taxpayer to pay to the United States a penalty not in excess of $25,000.
(2) **Counsel’s liability for excessive costs** — Whenever it appears to the Tax Court that any attorney or other person admitted to practice before the Tax Court has multiplied the proceedings in any case unreasonably and vexatiously, the Tax Court may require—
(A) that such attorney or other person pay personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct, or
(B) if such attorney is appearing on behalf of the Commissioner of Internal Revenue, that the United States pay such excess costs, expenses, and attorneys’ fees in the same manner as such an award by a district court.
**(b) Proceedings in other courts**
(1) **Claims under section 7433** — Whenever it appears to the court that the taxpayer’s position in the proceedings before the court instituted or maintained by such taxpayer under section 7433 is frivolous or groundless, the court may require the taxpayer to pay to the United States a penalty not in excess of $10,000.
(2) **Collection of sanctions and costs** — In any civil proceeding before any court (other than the Tax Court) which is brought by or against the United States in connection with the determination, collection, or refund of any tax, interest, or penalty under this title, any monetary sanctions, penalties, or costs awarded by the court to the United States may be assessed by the Secretary and, upon notice and demand, may be collected in the same manner as a tax.
(3) **Sanctions and costs awarded by a court of appeals** — In connection with any appeal from a proceeding in the Tax Court or a civil proceeding described in paragraph (2), an order of a United States Court of Appeals or the Supreme Court awarding monetary sanctions, penalties or court costs to the United States may be registered in a district court upon filing a certified copy of such order and shall be enforceable as other district court judgments. Any such sanctions, penalties, or costs may be assessed by the Secretary and, upon notice and demand, may be collected in the same manner as a tax.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** In any administrative or court proceeding which is brought by or against the United States in connection with the determination, collection, or refund of any tax, interest, or penalty under this title, the prevailing party may be awarded a judgment or a settlement for—
(1) reasonable administrative costs incurred in connection with such administrative proceeding within the Internal Revenue Service, and
(2) reasonable litigation costs incurred in connection with such court proceeding.
**(b) Limitations**
(1) **Requirement that administrative remedies be exhausted** — A judgment for reasonable litigation costs shall not be awarded under subsection (a) in any court proceeding unless the court determines that the prevailing party has exhausted the administrative remedies available to such party within the Internal Revenue Service. Any failure to agree to an extension of the time for the assessment of any tax shall not be taken into account for purposes of determining whether the prevailing party meets the requirements of the preceding sentence.
(2) **Only costs allocable to the United States** — An award under subsection (a) shall be made only for reasonable litigation and administrative costs which are allocable to the United States and not to any other party.
(3) **Costs denied where party prevailing protracts proceedings** — No award for reasonable litigation and administrative costs may be made under subsection (a) with respect to any portion of the administrative or court proceeding during which the prevailing party has unreasonably protracted such proceeding.
(4) **Period for applying to IRS for administrative costs** — An award may be made under subsection (a) by the Internal Revenue Service for reasonable administrative costs only if the pr
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 7430
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Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** If, in connection with any collection of Federal tax with respect to a taxpayer, any officer or employee of the Internal Revenue Service recklessly or intentionally, or by reason of negligence, disregards any provision of this title, or any regulation promulgated under this title, such taxpayer may bring a civil action for damages against the United States in a district court of the United States. Except as provided in section 7432, such civil action shall be the exclusive remedy for recovering damages resulting from such actions.
**(b) Damages** In any action brought under subsection (a) or petition filed under subsection (e), upon a finding of liability on the part of the defendant, the defendant shall be liable to the plaintiff in an amount equal to the lesser of $1,000,000 ($100,000, in the case of negligence) or the sum of—
(1) actual, direct economic damages sustained by the plaintiff as a proximate result of the reckless or intentional or negligent actions of the officer or employee, and
(2) the costs of the action.
**(c) Payment authority** Claims pursuant to this section shall be payable out of funds appropriated under [section 1304 of title 31](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title31-section1304&num=0&edition=prelim), United States Code.
**(d) Limitations**
(1) **Requirement that administrative remedies be exhausted** — A judgment for damages shall not be awarded under subsection (b) unless the court determines that the plaintiff has exhausted the administrative remedies available to such plaintiff within the Internal Revenue Service.
(2) **Mitigation of damages** — The amount of damages awarded under subsection (b)(1) shall be reduced by the amount of such damages which could have reasonably been mitigate
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 7433
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Jurisdiction**
(1) **In general** — The United States Courts of Appeals (other than the United States Court of Appeals for the Federal Circuit) shall have exclusive jurisdiction to review the decisions of the Tax Court, except as provided in [section 1254 of Title 28](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title28-section1254&num=0&edition=prelim) of the United States Code, in the same manner and to the same extent as decisions of the district courts in civil actions tried without a jury; and the judgment of any such court shall be final, except that it shall be subject to review by the Supreme Court of the United States upon certiorari, in the manner provided in [section 1254 of Title 28](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title28-section1254&num=0&edition=prelim) of the United States Code.
(2) **Interlocutory orders**
(A) *In general* — When any judge of the Tax Court includes in an interlocutory order a statement that a controlling question of law is involved with respect to which there is a substantial ground for difference of opinion and that an immediate appeal from that order may materially advance the ultimate termination of the litigation, the United States Court of Appeals may, in its discretion, permit an appeal to be taken from such order, if application is made to it within 10 days after the entry of such order. Neither the application for nor the granting of an appeal under this paragraph shall stay proceedings in the Tax Court, unless a stay is ordered by a judge of the Tax Court or by the United States Court of Appeals which has jurisdiction of the appeal or a judge of that court.
(B) *Order treated as Tax Court decision* — For purposes of subsections (b) and (c), an order described in this pa
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 7482
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Federal law — U.S. Code and appendices · legal_authorities
Page 3787
TITLE 26—INTERNAL REVENUE CODE
§ 6673
subsection (a) [amending this section and sections 6694
and 6703 of this title] shall take effect on the date of
the enactment of this Act [Dec. 19, 1989].’’
EFFECTIVE DATE OF 1978 AMENDMENT
Pub. L. 95–628, § 9(c), Nov. 10, 1978, 92 Stat. 3633, pro-
vided that: ‘‘The amendments made by this section
[amending this section and sections 7103 and 7421 of this
title] shall apply with respect to penalties assessed
more than 60 days after the date of the enactment of
this Act [Nov. 10, 1978].’’
PUBLIC
INFORMATION
TO
ENSURE
EMPLOYEE
AWARE-
NESS
OF
RESPONSIBILITIES
AND
LIABILITIES
UNDER
TAX DEPOSITORY SYSTEM
Pub. L. 104–168, title IX, § 904(b), July 30, 1996, 110
Stat. 1467, provided that:
‘‘(1) IN GENERAL.—The Secretary of the Treasury or
the Secretary’s delegate (hereafter in this subsection
referred to as the ‘Secretary’) shall take such actions
as may be appropriate to ensure that employees are
aware of their responsibilities under the Federal tax
depository system, the circumstances under which em-
ployees may be liable for the penalty imposed by sec-
tion 6672 of the Internal Revenue Code of 1986, and the
responsibility to promptly report to the Internal Rev-
enue Service any failure referred to in subsection (a) of
such section 6672. Such actions shall include—
‘‘(A) printing of a warning on deposit coupon book-
lets and the appropriate tax returns that certain em-
ployees may be liable for the penalty imposed by such
section 6672, and
‘‘(B) the development of a special information
packet.
‘‘(2) DEVELOPMENT OF EXPLANATORY MATERIALS.—The
Secretary shall develop materials explaining the cir-
cumstances under which board members of tax-exempt
organizations (including voluntary and honorary mem-
bers) may
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6673
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