(1)
(a) Except as provided in Subsection (1)(b), a taxpayer that fails to disclose a reportable transaction as required by Section 59-1-1303 is subject to a penalty of $15,000.
(b) A taxpayer that fails to disclose a listed transaction as required by Section 59-1-1303 is subject to a penalty of $30,000.
(2) A penalty imposed by this section is in addition to any other penalty imposed by this title.