(a) Civil penalty 
In addition to any other penalty provided by law, any regulated investment company whose tax liability for any taxable year is deemed to be increased pursuant to section 860 (c)(1)(A) shall pay a penalty in an amount equal to the amount of the interest (for which such company is liable) which is attributable solely to such increase.

(b) 50-percent limitation 
The penalty payable under this section with respect to any determination shall not exceed one-half of the amount of the deduction allowed by section 860 (a) for such taxable year.

(c) Deficiency procedures not to apply 
Subchapter B of chapter 63 (relating to deficiency procedure for income, estate, gift, and certain excise taxes) shall not apply in respect of the assessment or collection of any penalty imposed by subsection (a).