PUBLIC LAW 99-514—OCT. 22, 1986
100 STAT. 2743
unless some part of the underpayment is due to the fraud of such spouse." (b) SPECIAL RULE FOR INTEREST OR DIVIDEND PAYMENTS EXTENDED TO OTHER AMOUNTS SHOWN ON INFORMATION RETURNS.—Subsection
(g) of section 6653 (relating to special rule in the case of interest or dividend payments) is amended to read as follows: "(g) SPECIAL RETURNS.—If—
"(1) any amount is shown on— "(A) an information return (as defined in section • • 6724(d)(1)), or "(B) a return filed under section 6031, section 6037, section 6012(a) by an estate or trust, section 6050B, or section
6050E,and "(2) the payee (or other person with respect to whom the return is made) fails to properly show such amount on his return, any portion of an underpayment attributable to such failure shall be treated, for purposes of subsection (a), as due to negligence in the absence of clear and convincing evidence to the contrary." (c) CONFORMING AMENDMENTS.—
(1) Subsection (d) of section 6222 is amended by striking out "intentional or negligent". (2) Subsection (d) of section 6653 is amended by striking out "same underpayment" and inserting in lieu thereof "portion of the underpayment which is attributable to fraud". (3) Subsection (f) of section 6653 is amended by striking out "or intentional disregard of rules and regulations (but without intent to defraud)". (d) CHANGE IN SECTION HEADING.—
(1) The heading for section 6653 (relating to failure to pay tax) is amended to read as follows: "SEC. 6653. ADDITIONS TO TAX FOR NEGLIGENCE AND FRAUD."
(2) The item relating to section 6653 in the table of sections for subpart A of chapter 68 is amended to read as follows: "Sec. 6653. Additions to tax for negligence and fraud."
(e) EFFECTIVE DATE.—The amendments made by this section shall apply to returns the due date for which (determined without regard to extensions) is after December 31, 1986. SEC. 1504. INCREASE IN PENALTY FOR SUBSTANTIAL UNDERSTATEMENT OF LIABILITY.
(a) IN GENERAL.—Subsection (a) of section 6661 (relating to substantial understatement of liability) is amended by striking out "10 percent" and inserting in lieu thereof "20 percent". (b) EFFECTIVE DATE.—The amendment made by this section shall apply to returns the due date for which (determined without regard to extensions) is after December 31, 1986.