(1)
(a) Except as provided in paragraph (b) of this subsection (1), a taxpayer that fails to disclose a reportable transaction as required by section 39-22-653 shall be subject to a penalty of up to fifteen thousand dollars.
(b) A taxpayer that fails to disclose a listed transaction as required by section 39-22-653 shall be subject to a penalty of up to fifty thousand dollars.
(2) Any penalty imposed by this section shall be in addition to any other penalty imposed by articles 21 and 22 of this title.
(3) For purposes of this section, if two or more members of the same combined report or consolidated return participate in the same reportable or listed transaction, the penalty imposed by subsection (1) of this section shall only be imposed once on the combined report or consolidated return.
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