CODIFICATION OF INTERNAL REVENUE LAWS Supplement M-Interest and Additions to the Tax SEC. 291 . FAILURE TO FILE RETURN. In case of any failure to make and file return required by this chap- ter, within the time prescribed by law or prescribed by the Commis- sioner in pursuance of law, unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the tax: 5 per centum if the failure is for not more than thirty days with an additional 5 per centum for each additional thirty days or fraction thereof during which such failure continues, not exceeding 25 per centum in the aggregate. The amount so added to any tax shall be collected at the same time and in the same man- ner and as a part of the tax unless the tax has been paid before the discovery of the neglect, in which case the amount so added shall be collected in the same manner as the tax. The amount added to the tax under this section shall be in lieu of the 25 per centum addition to the tax provided in section 3612 (d) (1). SEC. 292. INTEREST ON DEFICIENCIES. Interest upon the amount determined as a deficiency shall be assessed at the same time as the deficiency, shall be paid upon notice and demand from the collector, and shall be collected as a part of the tax, at the rate of 6 per centum per annum from the date pre- scribed for the payment of the tax (or, if the tax is paid in install- ments, from the date prescribed for the payment of the first install- ment) to the date the deficiency is assessed, or, in the case of a waiver under section 272 (d), to the thirtieth day after the filing of such waiver or to the date the deficiency is assessed whichever is the earlier. SEC. 293. ADDITIONS TO THE TAX IN CASE OF DEFICIENCY. (a) NEGLIGENCE. - If any part of any deficiency is due to negligence, or intentional disregard of rules and regulations but without intent to defraud, 5 per centum of the total amount of the deficiency (in addi- tion to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency, except that the provisions of section 272 (i), relating to the prorating of a deficiency, and of section 292, relating to interest on deficiencies, shall not be applicable. (b) FRAUD.- If any part of any deficiency is due to fraud with in- tent to evade tax, then 50 per centum of the total amount of the de- ficiency (in addition to such deficiency) shall be so assessed, collected, and paid, in lieu of the 50 per centum addition to the tax provided in section 3612 (d) (2). SEC. 294. ADDITIONS TO THE TAX IN CASE OF NONPAYMENT. (a) TAX SHOWN ON RETURN.- (1) GENERAL RULE. - Where the amount determined by the tax- payer as the tax imposed by this chapter, or any installment thereof, or any part of such amount or installment, is not paid on or before the date prescribed for its payment, there shall be col- lected as a part of the tax, interest upon such unpaid amount at the rate of 6 per centum per annum from the date prescribed for its payment until it is paid. (2) IF EXTENSION GRANTED. -W here an extension of time for pay- ment of the amount so determined as the tax by the taxpayer, or any installment thereof, has been granted, and the amount the time for payment of which has been extended, and the interest thereon deter- mined under section 295, is not paid in full prior to the expiration of the period of the extension, then, in lieu of the interest provided for in paragraph (1) of this subsection, interest at the rate of 6 per centum per annum shall be collected on such unpaid amount from the date of the expiration of the period of the extension until it is paid. 88
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