Transparent political-donation deduction claims do not alone constitute misreporting, permitting statutory immunity from under-reporting penalties.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Political-donation deduction claims transparently disclosed in a return do not constitute misreporting merely because the deduction is disallowed. Misreporting requires material showing false evidence, suppression of facts, or deliberate misrepresentation. Statutory immunity from under-reporting penalties applies where the substantive conditions for immunity are satisfied. Applying these principles, the penalty imposed for alleged misreporting in relation to the political-donation deduction was deleted.....