Treasury Regulations · 26 CFR
§ 1.547-5. Deduction denied in case of fraud or wilful failure to file timely return.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 547
Cite as 26 CFR § 1.547-5
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Source
- T.D. 6500, 25 FR 11402, Nov. 26, 1960; 25 FR 14021, Dec. 21, 1960; T.D. 9989, 89 FR 17606, Mar. 11, 2024, unless otherwise noted.
- Issued under
- 26 U.S.C. § 547
- Length
- 68 words · about 1 min to read
- Cross-references
- cites 1 Code section and 1 regulation; cited by 0
No deduction for deficiency dividends shall be allowed under section 547(a) if the determination contains a finding that any part of the deficiency is due to fraud with intent to evade tax, or to wilful failure to file an income tax return within the time prescribed by law or prescribed by the Secretary or his delegate in pursuance of law. See § 1.547-7 for effective date.
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Personal Holding Companies
Nearby sections
- § 1.547-1 General rule.
- § 1.547-2 Requirements for deficiency dividends.
- § 1.547-3 Claim for credit or refund.
- § 1.547-4 Effect on dividends paid deduction.
- § 1.547-5 Deduction denied in case of fraud or wilful failure to file timely return.
- § 1.547-6 Suspension of statute of limitations and stay of collection.
- § 1.547-7 Effective date.