StacksVerified U.S. regulatory reference

27 CFR §479.51

Verified against eCFR.gov as of June 20, 2026View official text on eCFR.gov
If any part of any underpayment of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 50 percent of the underpayment, but no delinquency penalty shall be assessed with respect to the same underpayment (section 6653, I.R.C.).