Upon a finding by the district director that any taxpayer violated, or attempted to violate, section 6851 (relating to termination of taxable year) there shall, in addition to all other penalties, be added as part of the tax 25 percent of the total amount of the tax or deficiency in the tax.
source: 32 FR 15241, Nov. 3, 1967, unless otherwise noted.
cite as: 26 CFR 301.6658-1