Page 24

- 24 -

the "2-percent portion" (for purposes of calculating interest under § 6601(j)) of the estate tax extended as provided in § 6166 is $1,490,000. .46 Failure to File Tax Return. For tax years beginning in 2017, the amount of the additional tax under § 6651(a) for failure to file a tax return within 60 days of the due date of such return (determined with regard to any extensions of time for filing) shall not be less than the lesser of $210 or 100 percent of the amount required to shown as tax on such returns. .47 Failure to File Certain Information Returns, Registration Statements, etc. For tax years beginning in 2017, the penalty amounts under § 6652(c) are: (1) for failure to file a return required under § 6033(a)(1) (relating to returns by exempt organization) or § 6012(a)(6) (relating to returns by political organizations): Scenario Daily Penalty Maximum Penalty Organization (§ 6652(c)(1)(A)) $20 Lessor of $10,000 or 5% of gross receipts of the organization for the year. Organization with gross receipts exceeding $1,028,500 (§ 6652(c)(1)(A))

$100

$51,000 Managers (§ 6652(c)(1)(B)) $10 $5,000 Public inspection of annual returns and reports (§ 6652(c)(1)(C)) $20 $10,000 Public inspection of applications for exemption and notice of status (§ 6652(c)(1)(D)) $20 No Limits

(2) for failure to file a return required under § 6034 (relating to returns by certain trust) or § 6043(b) (relating to terminations, etc., of exempt organizations): Scenario Daily Penalty Maximum Penalty Organization or trust (§ 6652(c)(2)(A)) $10 $5,000