103 STAT. 2404 PUBLIC LAW 101-239—DEC. 19, 1989 "(3) COORDINATION WITH SECTION 6700. —No penalty shall be assessed under section 6700 on any person with respect to any document for which a penalty is assessed on such person under subsection (a)." (2) TECHNICAL AMENDMENT.— Paragraph (1) of section 6701(f) is amended by striking "paragraph (2) and inserting "para- graphs (2) and (3)". 26 USC 6701 (c) EFFECTIVE DATE. —The amendments made by this section shall note. take effect on December 31, 1989. SEC. 7736. MODIFICATION TO PENALTY FOR FRIVOLOUS INCOME TAX RETURN. (a) REQUIREMENT OF FULL PAYMENT OF PENALTY. —Subsection (c) of section 6703 is amended by striking "section 6700, 6701, or 6702" each place it appears and inserting "section 6700 or 6701". 26 USC 6703 (b) EFFECTIVE DATE. —The amendment made by subsection (a) "°*®- shall apply to returns filed after December 31, 1989. SEC. 7737. AUTHORITY TO COUNTERCLAIM FOR BALANCE OF PENALTY IN PARTIAL REFUND SUITS. (a) GENERAL RULE. — Sections 6672(b)(l), 6694(c)(l), and 6703(c)(l) are each amended by adding at the end thereof the following new sentence: "Nothing in this paragraph shall be construed to prohibit any counterclaim for the remainder of such penalty in a proceeding begun as provided in paragraph (2)." 26 USC 6672 (b) EFFECTIVE DATE.—The amendment made by subsection (a) ^°*®- shall take effect on the date of the enactment of this Act. SEC. 7738. REPEAL OF BONDING REQUIREMENT UNDER SECTION 7407. (a) GENERAL RULE. —Subsection (c) of section 7407 (relating to bond to stay injunction) is hereby repealed. (b) CONFORMING AMENDMENT.—Subsection (a) of section 7407 is amended by striking "Except as provided in subsection (c), a civil" and inserting "A civil". 26 USC 7407 (c) EFFECTIVE DATE. —The amendments made by this section shall ^°*®- apply to actions commenced after December 31, 1989. SEC. 7739. CERTAIN DISCLOSURES OF INFORMATION BY PREPARERS PER- MITTED. (a) GENERAL RULE. —Paragraph (3) of section 7216(b) (relating to exceptions) is amended by adding at the end thereof the following new sentence: "Such regulations shall permit (subject to such condi- tions as such regulations shall provide) the disclosure or use of information for quality or peer reviews." 26 USC 7216 (b) EFFECTIVE DATE.—The amendment made by subsection (a) »ote. shall take effect on the date of the enactment of this Act. PART IV—FAILURES TO FILE OR PAY SEC. 7741. INCREASE IN PENALTY FOR FRAUDULENT FAILURE TO FILE. (a) GENERAL RULE.— Section 6651 (relating to failure to file tax return or pay tax) is amended by adding at the end thereof the following new subsection: "(f) INCREASE IN PENALTY FOR FRAUDULENT FAILURE TO FILE.—I f any failure to file any return is fraudulent, paragraph (1) of subsec- tion (a) shall be applied—
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