transfer, directly or indirectly, between persons specified within any one of the paragraphs of section 267(b) or persons described in section 707(b); except that, in applying section 267(b) and (c) and

(b) EnforcementWhenever any person summoned under section 6420(e)(2), 6421(g)(2), 6427(j)(2), or 7602 neglects or refuses to obey such summons, or to produce books, papers, records, or other data, or to give testimony, as required, the Secretary may apply to the judge of the district court or to a United States magistrate judge for the district within which the person so summoned resides

effect under subsections (a) and (b) of section 3101 and subsections (a) and (b) of section 3111 for the calendar year. (b) Tier 2 taxIn addition to other taxes, there is hereby imposed on the income of each employee representative a tax equal to the

(a) In general. Section 6664(a) defines the term “underpayment” for purposes of the accuracy-related penalty under section 6662 and the fraud penalty under section 6663. The definition of “underpayment” of income taxes imposed under subtitle A is set forth in §1.6664-2. Ordering rules for computing the total amount of accuracy