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Misreporting penalties for under-reporting require identification of a specific statutory form of misreporting and evidence of its factual nexus with the assessee. Withdrawal of a political-party donation deduction after a reassessment notice, without more, does not establish misreporting. A political party's alleged general modus operandi is insufficient without material linking the assessee to the arrangement, return of the donation in cash, or knowing participation in an accommodation-entry transaction. On these facts, the enhanced penalty for misreporting was deleted.
Misreporting penalties for under-reporting require identification of a specific statutory form of misreporting and evidence of its factual nexus with the assessee. Withdrawal of a political-party donation deduction after a reassessment notice, without more, does not establish misreporting. A political party's alleged general modus operandi is insufficient without material linking the assessee to the arrangement, return of the donation in cash, or knowing participation in an accommodation-entry transaction. On these facts, the enhanced penalty for misreporting was deleted.
Note: It is a system-generated summary and is for quick reference only.