Penalty liability amendment clarifies authority inclusion and limits assumed tax charge by changing penalty wording. Amendments to section 271 expand referenced authority by inserting the Commissioner alongside Commissioner (Appeals) in the opening portion and specified explanations, rephrase penalty language from 'in addition to any tax payable' to 'in addition to tax, if any, payable,' omit an Explanation limiting application to taxpayers not previously assessed, and substitute the computation rule to treat concealed or inaccurately reported income as if it were the total income where it reduces declared loss or converts loss into income.
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Penalty liability amendment clarifies authority inclusion and limits assumed tax charge by changing penalty wording.
Amendments to section 271 expand referenced authority by inserting the Commissioner alongside Commissioner (Appeals) in the opening portion and specified explanations, rephrase penalty language from "in addition to any tax payable" to "in addition to tax, if any, payable," omit an Explanation limiting application to taxpayers not previously assessed, and substitute the computation rule to treat concealed or inaccurately reported income as if it were the total income where it reduces declared loss or converts loss into income.
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