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Treasury Regulations · 26 CFR

§ 301.6684-1. Assessable penalties with respect to liability for tax under chapter 42.

In effect eCFR current as of October 15, 2026

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. § 6684

Cite as 26 CFR § 301.6684-1

At a glance

Read from the text and its source citation. Not part of the regulation.

Status
In the current eCFR
Issued
June 15, 1971 by T.D. 7127
Issued under
26 U.S.C. § 6684
Length
250 words · about 1 min to read
Defines
1 term
Cross-references
cites 4 Code sections and 0 regulations; cited by 0
(a) In general. If any person (as defined in section 7701(a)(1)) becomes liable for tax under any section of chapter 42 (other than section 4940 or 4948(a)), relating to private foundations, by reason of any act or failure to act which is not due to reasonable cause and either—
(1) Such person has theretofore (at any time) been liable for tax under any section of such chapter (other than section 4940 or 4948(a)), or
(2) Such act or failure to act is both willful and flagrant,

then such person shall be liable for a penalty equal to the amount of such tax.

(b) Showing of reasonable cause. The penalty imposed by section 6684 shall not apply to any person with respect to a violation of any section of chapter 42 if it is established to the satisfaction of the district director or director of the internal revenue service center that such violation was due to reasonable cause. An affirmative showing of reasonable cause must be made in the form of a written statement, containing a declaration by such person that it is made under the penalties of perjury, setting forth all the facts alleged as reasonable cause.
(c) Willful and flagrant. For purposes of this section, the term “willful and flagrant” has the same meaning as such term possesses in section 507(a)(2)(A) and the regulations thereunder.
(d) Effective date. This section shall take effect on January 1, 1970.

[T.D. 7127, 36 FR 11504, June 15, 1971]

Terms defined here

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Cross-references

Computed from the citations in the text of 26 CFR.

Code sections it cites

Amendment history

From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.

  1. Issued by T.D. 7127 (36 FR 11504)

Where it sits in 26 CFR

  1. Subchapter F Procedure and administration
  2. Part 301 Procedure and administration
  3. Subpart ECFRe7a848e7ecebb4b Additions to the Tax, Additional Amounts, and Assessable Penalties
  4. Additions to the Tax and Additional Amounts

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