| Section 512 of the bill would add a penalty for understatements of tax for transactions lacking economic substance. |
| The provisions of section 6662 relating to substantial overstatements of pension liabilities and substantial estate or gift tax valuation understatements are not addressed. |
| Accuracy-related penalties include negligence, substantial understatements and substantial overstatements. |
| The Internal Revenue Code imposes an accuracy-related penalty on understatements of tax. |
| As with prior law, an innocent spouse election is available only for understatements the IRS has already assessed, not for unpaid tax obligations shown on a filed return. |
| To say the man was large would be an understatement beyond all understatements. |
