26 U.S.C. § 6658 — Coordination with title 11

(a) Certain failures to pay tax No addition to the tax shall be made under section 6651, 6654, or 6655 for failure to make timely payment of tax for a period during which a case is pending under title 11 of the United States Code— (1) if that tax was incurred by the estate and the failure occurred under an order of the court finding probable insufficiency of funds of the estate to pay administrative expenses, or (2) if— (A) that tax was incurred by the debtor before the earlier of the order for relief or (in the involuntary case) the appointment of a trustee, and (B) (i) the petition was filed before the due date prescribed by law (including extensions) for filing a return of that tax, or (ii) the date for making the addition to the tax occurs on or after the day on which the petition was filed. (b) Exception for collected taxes Subsection (a) must not apply to any liability for an addition to the tax which arises from the failure to pay or deposit a tax withheld or collected from others and required to be paid to the United States.