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Section 6103(l)(21) does not permit the Treasury Department or the IRS to establish penalties under these regulations
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https://www.irs.gov/node/49746
gov websites use HTTPS A lock () or https:// means you've safely connected to the

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https://www.irs.gov/publications/p519
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https://www.irs.gov/publications/p17
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https://www.irs.gov/irb/2025-01_IRB
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https://www.irs.gov/instructions/iw7
If an ITIN is applied for on or before the due date of a return (including extensions) and the IRS issues an ITIN as a result of the application, the IRS will consider the ITIN as issued on or before the due date of the return