[Code of Federal Regulations]
[Title 26, Volume 7]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.547-5]

[Page 283]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.547-5  Deduction denied in case of fraud or wilful failure to 
file timely return.

    No deduction for deficiency dividends shall be allowed under section 
547(a) if the determination contains a finding that any part of the 
deficiency is due to fraud with intent to evade tax, or to wilful 
failure to file an income tax return within the time prescribed by law 
or prescribed by the Secretary or his delegate in pursuance of law. See 
Sec. 1.547-7 for effective date.