OF PENALTY.—The penalty imposed under subparagraph (A)— (i) shall be treated as a penalty for purposes of subtitle F of the Internal Revenue Code of 1986, (ii) shall be paid on notice and demand by the Secretary and in the same manner as tax under such Co (0)

by TREATMENT
Venue:2) UNITED STATES.—The term ‘‘United States’’ means the several States, the District of Columbia, the Commonwealth of Puerto Rico, and the possessions of the