Minor breach exemption limits penalties and mandates proportionality, hearing, specification of breach and mitigation for voluntary disclosure.

No penalty shall be imposed for minor breaches-defined by a statutory tax threshold and errors apparent on the face of the record-provided they are without fraud or gross negligence; fixed-sum or fixed-percentage penalties are excluded. Penalties must be proportional to the breach, may not be imposed without an opportunity to be heard, and must identify the nature of the breach and the statutory provision. Voluntary disclosure prior to discovery may be considered a mitigating factor in quantifying penalty.

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