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21 .52 Interest on a Certain Portion of the Estate Tax Payable in Installments. For an estate of a decedent dying in calendar year 2025, the dollar amount used to determine the “2- percent portion” (for purposes of calculating interest under § 6601(j)) of the estate tax extended as provided in § 6166 is $1,900,000. .53 Failure to File Tax Return. In the case of any return required to be filed in 2026, the amount of the addition to tax under § 6651(a) for failure to file an income tax return within 60 days of the due date of such return (determined with regard to any extensions of time for filing) will not be less than the lesser of $525 or 100 percent of the amount required to be shown as tax on such return. .54 Failure to File Certain Information Returns, Registration Statements, etc. For returns required to be filed in 2026, 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)) $25 Lesser of $13,000 or 5% of gross receipts of the organization for the year. Organization with gross receipts exceeding $1,309,500 (§ 6652(c)(1)(A)) $130 $65,000 Managers (§ 6652(c)(1)(B)) $10 $6,500 Public inspection of annual returns and reports (§ 6652(c)(1)(C)) $25 $13,000 Public inspection of applications for exemption and notice of status (§ 6652(c)(1)(D)) $25 No Limit