gross valuation misstatements
Defined in 1 place of the United States Code.
The term “gross valuation misstatements” means—
(A) any substantial valuation misstatement under chapter 1 as determined under subsection (e) by substituting—
(i) “400 percent” for “200 percent” each place it appears,
(ii) “25 percent” for “50 percent”, and
(iii) in paragraph (1)(B)(ii)—
(I) “$20,000,000” for “$5,000,000”, and
(II) “20 percent” for “10 percent”.
(B) any substantial overstatement of pension liabilities as determined under subsection (f) by substituting “400 percent” for “200 percent”, and
(C) any substantial estate or gift tax valuation understatement as determined under subsection (g) by substituting “25 percent” for “50 percent”.
Source
- 1994–200626 U.S.C. § 6662Internal Revenue Code · Imposition of accuracy-related penalty on underpayments · in this section
The term “gross valuation misstatements” means—
(A) any substantial valuation misstatement under chapter 1 as determined under subsection (e) by substituting—
(i) in paragraph (1)(A), “200 percent” for “150 percent”,
(ii) in paragraph (1)(B)(i)—
(I) “400 percent” for “200 percent”, and
(II) “25 percent” for “50 percent”, and
(iii) in paragraph (1)(B)(ii)—
(I) “$20,000,000” for “$5,000,000”, and
(II) “20 percent” for “10 percent”.
(B) any substantial overstatement of pension liabilities as determined under subsection (f) by substituting “400 percent” for “200 percent”, and
(C) any substantial estate or gift tax valuation understatement as determined under subsection (g) by substituting “40 percent” for “65 percent”.
Source
- 2006–202226 U.S.C. § 6662Internal Revenue Code · Imposition of accuracy-related penalty on underpayments · in this section
The term "gross valuation misstatements" means—
(A) any substantial valuation misstatement under chapter 1 as determined under subsection (e) by substituting—
(i) in paragraph (1)(A), "200 percent" for "150 percent",
(ii) in paragraph (1)(B)(i)—
(I) "400 percent" for "200 percent", and
(II) "25 percent" for "50 percent", and
(iii) in paragraph (1)(B)(ii)—
(I) "$20,000,000" for "$5,000,000", and
(II) "20 percent" for "10 percent".
(B) any substantial overstatement of pension liabilities as determined under subsection (f) by substituting "400 percent" for "200 percent",
(C) any substantial estate or gift tax valuation understatement as determined under subsection (g) by substituting "40 percent" for "65 percent", and
(D) any disallowance of a deduction described in subsection (b)(10).
Source
- 2022–present26 U.S.C. § 6662Internal Revenue Code · Imposition of accuracy-related penalty on underpayments · in this section