Notice 2010-33, 2010-17 I.R.B. 609 (frivolous positions)

The record

Level

Legal authority

Authority

Notice 2010-33, 2010-17 I.R.B. 609 (frivolous positions)

Issued

2010-04-26 Apr. 26, 2010

In force

Apr. 26, 2010 (no end date recorded; counted as in force for 120 days)

Character

IRS notice

Operative words

(a) Civil penalty. If a claim for refund or credit with respect to income or employment tax is made for an excessive amount, unless it is shown that the claim for such excessive amount is due to reasonable cause, the person making such claim shall be liable for a penalty in an amount equal to 20 percent of the excessive amount. (sec. 6676(a), current text)... A person shall pay a penalty of $5,000 if-- (1) such person files what purports to be a return of a tax imposed by this title but which-- (A) does not contain information on which the substantial correctness of the self-assessment may be judged... (sec. 6702(a))... Positions that are the same as or similar to the positions listed in this notice are identified as frivolous for purposes of the penalty for a 'frivolous tax return' under section 6702(a)... (Notice 2010-33, sec. I)

Notes