The penalty for substantial understatement of tax liability does not apply if:

Name: The penalty for substantial understatement of tax liability does not apply if:
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The penalty for substantial understatement of tax liability does not apply if the taxpayer has substantial authority for the treatment taken on the tax return, the relevant facts affecting the treatment are adequately disclosed in the return or on Form 8275, or the IRS failed to meet its burden of proof in showing the taxpayer's error.

The Penalty for Substantial Understatement of Tax Liability Does Not