651w

(a) Negligence.— If any portion of any deficiency shall be due to negligence or intentional disregard of the rules and regulations, but without intention to defraud, there shall be assessed five percent (5%) of the total amount of the deficiency (in addition to said deficiency) and it shall be collected and paid in the same manner as if it were a deficiency, except that the provisions of § 651v of this title relating to interest on deficiencies shall not apply.(b) Fraud.— If any portion of any deficiency should arise from fraud with the intention of tax evasion, then fifty percent (50%) of the whole amount of the deficiency (in addition to said deficiency) shall be so assessed, collected and paid. History —July 10, 1974, No. 113, Part 1, p. 371, § 24.