26 U.S.C. § 6671
Section 6671 · Rules for application of assessable penalties
Amended 2 times on record
Applied in 360 court decisions — leading case United States v. Sotelo (1978)
Most recently applied in Alon Farhy v. Cmsnr. IRS (May 2024)
Cases citing this section usually also cite 26 U.S.C. § 6672 · 26 U.S.C. § 7501 · 26 U.S.C. § 3102
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
The penalties and liabilities provided by this subchapter shall be paid upon notice and demand by the Secretary, and shall be assessed and collected in the same manner as taxes. Except as otherwise provided, any reference in this title to “tax” imposed by this title shall be deemed also to refer to the penalties and liabilities provided by this subchapter.
The term “person”, as used in this subchapter, includes an officer or employee of a corporation, or a member or employee of a partnership, who as such officer, employee, or member is under a duty to perform the act in respect of which the violation occurs.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary”.
Cross References
Failure to pay stamp tax, additions to tax for, see section 6653 of this title.
Notice and demand for tax, see section 6303 of this title.
Payment on notice and demand, see section 6155 of this title.