Restrictions on taxpayers who improperly claimed credit in prior year
(1) Taxpayers making prior fraudulent or reckless claims
(1)Taxpayers making prior fraudulent or reckless claims∀ 2#
(A) In general No credit shall be allowed under this section for any taxable year in the disallowance period.
(B) Disallowance period For purposes of subparagraph (A), the disallowance period is— (i) the period of 10 taxable years after the most recent taxable year for which there was a final determination that the taxpayer’s claim of credit under this section was due to fraud, and (ii) the period of 2 taxable years after the most recent taxable year for which there was a final determination that the taxpayer’s claim of credit under this section was due to reckless or intentional disregard of rules and regulations (but not due to fraud).
(2)Taxpayers making improper prior claims#
In the case of a taxpayer who is denied credit under this section for any taxable year as a result of the deficiency procedures under subchapter B of chapter 63, no credit shall be allowed under this section for any subsequent taxable year unless the taxpayer provides such information as the Secretary may require to demonstrate eligibility for such credit.