103 STAT. 2400 PUBLIC LAW 101-239—DEC. 19, 1989 (7) Subsection (d) of section 6222 is amended by striking "section 6653(a)" and inserting "part II of subchapter A of chapter 68". (8) Paragraph (2) of section 6601(e) is amended by striking "section 6651(a)(l), 6653, 6659, 6660, or 6661" each place it appears and inserting "section 6651(a)(l) or 6653 or under part II of subchapter A of chapter 68". (9) Subsection (a) of section 6672 is amended by striking "under section 6653" and inserting "under section 6653 or part II of subchapter A of chapter 68". (10) Subparagraph (C) of section 461(i)(3) is amended by strik- ing "section 6662(b)(2)(C)(ii)" and inserting '^section 6662(d)(2)(C)(ii)". (11) Clause (i) of section 1274(b)(3)(B) is amended by striking "section 6661(b)(2)(C)(ii)" and inserting "section 6662(d)(2)(C)(ii)'. (12) Subparagraph (B) of section 7519(fK4) is amended by striking "section 6653" and inserting "part II of subchapter A of chapter 68". (13) Subchapter A of chapter 68 is amended by inserting after the subchapter heading the following: J "Part I. General provisions. "Part n. Accuracy-related and fraud penalties. "Part ni. Applicable rules. "PART I—GENERAL PROVISIONS". (14) The table of sections for part I of subchapter A of chapter 68 (as amended by paragraph (1)) is amended— (A) by stnking out the items relating to sections 6659, - 6659A, 6660, and 6661, and (B) by striking the item relating to section 6653 and inserting: "Sec. 6653. Failure to pay stamp tax." 26 USC 461 note. (d) 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, 1989. PART III—PREPARER, PROMOTER, AND PROTESTER PENALTIES SEC. 7731. PENALTY FOR INSTITUTING PROCEEDINGS BEFORE TAX COURT PRIMARILY FOR DELAY, ETC (a) GENERAL RULE. —Section 6673 (relating to damages assessable for instituting proceedings before the Tax Court primcuily for delay, etc.) is amended to read as follows: "SEC. 6673. SANCTIONS AND COSTS AWARDED BY COURTS. "(a) TAX C!OURT PROCEEDINGS. — "(1) PROCEDURES INSTITUTED PRIMARILY FOR DELAY, ETC.— Whenever it appears to the Tax Court that— "(A) proceedings before it have been instituted or main- tained by the taxpayer primarily for delay, "(B) the taxpayer's position m such proceeding is frivo- lous or groundless, or
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