Limitation on penalty imposition limits timeframe for issuing or revising tax penalties after completion of proceedings or appeals. A six-month limitation measured from the end of the quarter bars imposition of penalties after specified triggering events-completion of proceedings where no appeal exists, passing of a revision order, receipt of an appellate order by the jurisdictional officer, or issuance of a notice for imposition. Penalty orders may be revised to reflect assessments revised on appeal or revision, but revision requires that the assessee be heard and must itself comply with the same six month limitation. Time for rehearing and periods of court-ordered stay are excluded in computing the limitation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Limitation on penalty imposition limits timeframe for issuing or revising tax penalties after completion of proceedings or appeals.
A six-month limitation measured from the end of the quarter bars imposition of penalties after specified triggering events-completion of proceedings where no appeal exists, passing of a revision order, receipt of an appellate order by the jurisdictional officer, or issuance of a notice for imposition. Penalty orders may be revised to reflect assessments revised on appeal or revision, but revision requires that the assessee be heard and must itself comply with the same six month limitation. Time for rehearing and periods of court-ordered stay are excluded in computing the limitation.
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