Immunity from penalty available when settlement proceedings abate and taxpayer cooperates fully, subject to conditions and withdrawal.

A new provision permits a taxpayer to apply for immunity from penalty after settlement proceedings have abated and before any penalty is imposed; the Commissioner may grant immunity, subject to conditions, where the taxpayer has cooperated post abatement and made a full and true disclosure, and may withdraw immunity for non compliance or if material concealment or false evidence is discovered, after which penalty provisions apply as if no immunity had been granted.

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