§6114. Treaty-based return positions — Inbound Citations

Citations to 26 U.S.C. § 6114 as a whole

• 26 U.S.C. § 6712(a)

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  (a) If a taxpayer fails to meet the requirements of section 6114, there is hereby imposed a penalty equal to $1,000 ($10,000 in the case of a C corporation) on each such failure.