Introduction›Part III. Administrative, Procedural, and Miscellaneous
SECTION 9. PENALTIES
Internal Revenue Bulletin 1997-13 · 2026-10-03 edition · updated 2026-10-04 · United States
The District Director may issue a Notice of Inadequate Records pursuant to § 1.6001–1(d) if the taxpayer’s books and records are available only as electronically stored books and records and the taxpayer’s electronic storage system fails to meet the requirements of this revenue procedure. Taxpayers whose electronic storage system fails to meet the requirements of this revenue procedure may also be subject to applicable penalties under subtitle F of the Code, including the § 6662(a) accuracy-related civil penalty and the § 7203 willful failure criminal penalty.
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