Waiver of penalty: full tax payment by notified date closes proceedings and prevents interest and penalty liability. The Government may waive penalty and late fee where a taxpayer pays the full tax due for specified past periods by a notified date in response to a notice or statement; on such payment interest and penalty are not payable and proceedings are deemed concluded, subject to exclusions for erroneous refunds and pending unwithdrawn appeals. If subsequent appellate or revisional orders create additional tax, that additional tax must be paid within a short period, with interest and penalty already paid and not refundable. Proceedings concluded under the waiver bar appeals against the originating notice or order.
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Provisions expressly mentioned in the judgment/order text.
Waiver of penalty: full tax payment by notified date closes proceedings and prevents interest and penalty liability.
The Government may waive penalty and late fee where a taxpayer pays the full tax due for specified past periods by a notified date in response to a notice or statement; on such payment interest and penalty are not payable and proceedings are deemed concluded, subject to exclusions for erroneous refunds and pending unwithdrawn appeals. If subsequent appellate or revisional orders create additional tax, that additional tax must be paid within a short period, with interest and penalty already paid and not refundable. Proceedings concluded under the waiver bar appeals against the originating notice or order.
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