{"id":"LAW-026","kind":"law","level":"law","jurisdiction":"","state":"","metro":"","industry":"","agency":"","eco":"","issuer":"Internal Revenue Service","authority":"Notice 2010-33, 2010-17 I.R.B. 609 (frivolous positions)","instrument":"Notice 2010-33, 2010-17 I.R.B. 609 (frivolous positions)","title":"Notice 2010-33, 2010-17 I.R.B. 609 (frivolous positions)","dateIssued":"2010-04-26","effective":"","end":"","startDate":"2010-04-26","endDate":"","quarters":[],"types":[],"addressees":[],"clause":"(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 \u0027frivolous tax return\u0027 under section 6702(a)... (Notice 2010-33, sec. I)","enforcement":"","functions":[],"notes":"I.R.B. page from the notice\u0027s own header; the Bulletin page not separately verified.","sourceUrl":"https://www.irs.gov/pub/irs-drop/n-10-33.pdf","snapshot":"","fileExists":true,"fileBytes":39359,"grade":"primary","character":"IRS notice","description":"","collection":"LEG-A","url":"/library/LAW-026","exhibitUrl":"/exhibit/LAW-026","citation":"Internal Revenue Service, Notice 2010-33, 2010-17 I.R.B. 609 (frivolous positions) (Apr. 26, 2010) (Ex. LAW-026)","stateName":"","related":[]}