Exempt Organizations Technical Guide›TG 65: Excise Taxes - Excess Benefit Transactions - IRC Section 4958›Table of Contents
Section 6684 - Assessable Penalties with Respect to Liability for Tax Under Chapter 42
0224 Publ 5835 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
(1) A disqualified person or an organization manager is liable for a penalty of 100% of
the applicable Section 4958 excise taxes if the disqualified person or organization manager is liable for Section 4958 excise taxes due to an act that isn’t due to reasonable cause, and:
a. The person was previously liable for chapter 42 excise taxes (other than
Sections 4940 or 4948), or
b. The act is both willful and flagrant. See Section 6684 and Treas. Reg.
301.6684-1.
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