APPLICATION OF FAILURE-TO-PAY PENALTY TO SUBSTITUTE RETURNS.

Sec. 1301. APPLICATION OF FAILURE-TO-PAY PENALTY TO SUBSTITUTE RETURNS. (a) General Rule.— Section 6651 (relating to failure to file tax return or to pay tax) is amended by adding at the end the following new subsection: “(g) Treatment of Returns Prepared By Secretary Under Section 6020(B).— In the case of any return made by the Secretary under section 6020(b)— “(1) such return shall be disregarded for purposes of determining the amount of the addition under paragraph (1) of subsection (a), but “(2) such return shall be treated as the return filed by the taxpayer for purposes of determining the amount of the addition under paragraphs (2) and (3) of subsection (a).”. (b) Effective Date.— The amendment made by subsection (a) shall apply in the case of tiny return the due date for which (determined without regard to extensions) is after the date of the enactment of this Act.