Public Law 119-73 (01/23/2026)

26 U.S.C. § 7203

Willful failure to file return, supply information, or pay tax

Any person required under this title to pay any estimated tax or tax, or required by this title or by regulations made under authority thereof to make a return, keep any records, or supply any information, who willfully fails to pay such estimated tax or tax, make such return, keep such records, or supply such information, at the time or times required by law or regulations, shall, in addition to other penalties provided by law, be guilty of a misdemeanor and, upon conviction thereof, shall be fined not more than $25,000 ($100,000 in the case of a corporation), or imprisoned not more than 1 year, or both, together with the costs of prosecution. In the case of any person with respect to whom there is a failure to pay any estimated tax, this section shall not apply to such person with respect to such failure if there is no addition to tax under section 6654 or 6655 with respect to such failure. In the case of a willful violation of any provision of section 6050I, the first sentence of this section shall be applied by substituting “felony” for “misdemeanor” and “5 years” for “1 year”.

Aug. 16, 1954, ch. 73668A Stat. 851Pub. L. 90–364, title I, § 103(e)(5)82 Stat. 264Pub. L. 97–248, title III96 Stat. 617Pub. L. 98–369, div. A, title IV, § 412(b)(9)98 Stat. 792Pub. L. 100–690, title VII, § 7601(a)(2)(B)102 Stat. 4504Pub. L. 101–647, title XXXIII, § 3303(a)104 Stat. 4918(, ; , , ; , §§ 327, 329(b), , , 618; , , ; , , ; , , .)

Editorial Notes

Amendments

Pub. L. 101–6471990— substituted “substituting ‘felony’ for ‘misdemeanor’ and” for “substituting”.

Pub. L. 100–6901988— inserted at end “In the case of a willful violation of any provision of section 6050I, the first sentence of this section shall be applied by substituting ‘5 years’ for ‘1 year’.”

Pub. L. 98–3691984— struck out “(other than a return required under the authority of section 6015)” after “to make a return”.

Pub. L. 97–248, § 329(b)1982—, substituted “$25,000 ($100,000 in the case of a corporation)” for “$10,000”.

Pub. L. 97–248, § 327, inserted last sentence providing that, in the case of any person with respect to whom there is a failure to pay any estimated tax, this section shall not apply to such person with respect to such failure if there is no addition to tax under section 6654 or 6655 with respect to such failure.

Pub. L. 90–3641968— struck out reference to section 6016.

Statutory Notes and Related Subsidiaries

Effective Date of 1990 Amendment

Pub. L. 101–647, title XXXIII, § 3303(c)104 Stat. 4918

“The amendment made by subsection (a) [amending this section] shall apply to actions, and failures to act, occurring after the date of the enactment of this Act [].”
, , , provided that:

Effective Date of 1988 Amendment

Pub. L. 100–690section 7601(a)(3) of Pub. L. 100–690section 6050I of this titleAmendment by applicable to actions after , see , set out as a note under .

Effective Date of 1984 Amendment

Pub. L. 98–369section 414(a)(1) of Pub. L. 98–369section 6654 of this titleAmendment by applicable with respect to taxable years beginning after , see , set out as a note under .

Effective Date of 1982 Amendment

section 329(b) of Pub. L. 97–248section 329(e) of Pub. L. 97–248section 7201 of this titleAmendment by applicable to offenses committed after , see , set out as a note under .

Effective Date of 1968 Amendment

Pub. L. 90–364section 104 of Pub. L. 90–364section 103(f) of Pub. L. 90–364section 243 of this titleAmendment by applicable with respect to taxable years beginning after , except as provided by , see , set out as a note under .