tion concerning the net value of assets appropriate to en-
force the tax imposed by this chapter. 
‘‘(b) METHOD OF REPORTING.—The Secretary shall, 
where appropriate, require the reporting made under sub-
section (a) to be made as a part of existing income report-
ing requirements (including requirements under chapter 
4 (relating to taxes to enforce reporting on certain foreign 
accounts)). 
‘‘(c) RESPONSIBILITY FOR REPORTING.—The Sec-
retary may impose reporting obligations by reference to 
the ownership, control, management, claim to income 
from, or other relationship to assets and liabilities for pur-
poses of administering the tax imposed by this section and 
may impose such obligations on financial institutions, 
business entities, or other persons, including requiring 
business entities to provide estimates of the value of the 
entity itself. 
‘‘SEC. 2905. ENFORCEMENT. 
‘‘The Secretary shall annually audit not less than 30 
percent of taxpayers required to pay the tax imposed 
under this chapter.’’. 
(b) NO DEDUCTION FROM INCOME TAXES.—Section 
275 of such Code is amended by inserting after paragraph 
(6) the following new paragraph: 
‘‘(7) Taxes imposed by chapter 18.’’. 
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(c) EXTENSION OF TIME FOR PAYMENT OF TAX.— 
(1) IN
GENERAL.—Section 6161(a) of such 
Code is amended by adding at the end the following 
new paragraph: 
‘‘(3) WEALTH TAX.— 
‘‘(A) IN GENERAL.—In the case of an ap-
plicable taxpayer described in subparagraph 
(B), the Secretary may extend the time for pay-
ment of the tax imposed under chapter 18 for 
a reasonable period not to exceed 5 years from 
the date fixed for the payment thereof. 
‘‘(B) TAXPAYERS DESCRIBED.—An appli-
cable taxpayer is described in this subparagraph 
if such the Secretary determines— 
‘‘(i) the applicable taxpayer has severe 
liquidity constraints, or 
‘‘(ii) immediate payment would cause 
undue hardship on an ongoing enterprise. 
‘‘(C) APPLICABLE
TAXPAYER.—For pur-
poses of this paragraph, the term ‘applicable 
taxpayer’ has the meaning given such term in 
section 2901.’’. 
(2) RULES.—Not later than 12 months after 
the date of the enactment of this Act, the Secretary 
of the Treasury (or the Secretary’s delegate) shall 
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establish rules for the application of the amend-
ments made by paragraph (1). 
(d) APPLICATION
OF ACCURACY RELATED PEN-
ALTIES.— 
(1) IN
GENERAL.—Section 6662(b) of such 
Code is amended by adding at the end the following 
new paragraph: 
‘‘(10) Any substantial wealth tax valuation un-
derstatement.’’. 
(2) SUBSTANTIAL WEALTH TAX UNDERSTATE-
MENT.—Section 6662 of such Code is amended by 
adding at the end the following new subsection: 
‘‘(m) APPLICATION TO SUBSTANTIAL WEALTH TAX 
VALUATION UNDERSTATEMENT.— 
‘‘(1) SUBSTANTIAL
WEALTH
TAX
VALUATION 
UNDERSTATEMENT DEFINED.— 
‘‘(A) IN GENERAL.—For purposes of this 
section, there is a substantial wealth tax valu-
ation understatement if the value of any prop-
erty claimed on any return of tax imposed by 
subtitle B–1 is 65 percent or less of the amount 
determined to be the correct amount of such 
valuation. 
‘‘(B) LIMITATION.—No penalty shall be 
imposed by reason of subsection (b)(10) unless 
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the portion of the underpayment attributable to 
substantial wealth tax valuation understate-
ments for the calendar year exceeds $5,000. 
‘‘(2) INCREASED PENALTY.— 
‘‘(A) IN
GENERAL.—In the case of any 
portion of an underpayment which is attrib-
utable to one or more substantial wealth tax 
valuation understatement, subsection (a) shall 
be applied— 
‘‘(i) in the case of a substantial wealth 
tax valuation understatement which is a 
gross wealth tax valuation misstatement, 
by substituting ‘50 percent’ for ‘20 per-
cent’, and 
‘‘(ii) in any other case, by substituting 
‘30 percent’ for ‘20 percent’. 
‘‘(B) GROSS
WEALTH
TAX
VALUATION 
MISSTATEMENT.—For purposes of subpara-
graph (A), the term ‘gross wealth tax valuation 
misstatement’ means a substantial wealth tax 
valuation understatement, as determined under 
paragraph (1) by substituting ‘40 percent’ for 
‘65 percent’.’’. 
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(e) EXEMPTION OF TAX EXEMPT ENTITIES.—Sec-
tion 501(a) of such Code is amended by inserting ‘‘and 
subtitle B–1’’ after ‘‘this subtitle’’. 
(f) CLERICAL AMENDMENT.—The table of subtitles 
of such Code is amended by inserting after the item relat-
ing to subtitle B the following new item: 
‘‘Subtitle B–1—Wealth Tax’’. 
(g) EFFECTIVE DATE.—The amendments made by 
this section shall apply to calendar years beginning after 
the date of the enactment of this Act. 
Æ 
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