Modifications of substantial understatement penalty for nonreportable transactions.
AJCA Section 819 modifies the Sec. 6662 definition of "substantial" for corporate taxpayers, to provide that there is a substantial understatement when the amount of the understatement for the tax year exceeds the lesser of 10% of the correct tax (or, if greater, $10,000) or $10 million.
The provision is effective for tax years beginning after Oct. 22, 2004. FROM PAUL MANNING, WASHINGTON, DC
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|Publication:||The Tax Adviser|
|Date:||Jan 1, 2005|
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