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)

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