(A) If any part of any underpayment of tax imposed by this subchapter is due to fraud, there shall be added to the tax an amount equal to 50% of the underpayment.
(B) In the case of failure to record a declaration required under this subchapter on the date prescribed therefor, unless it is shown that such failure is due to reasonable cause, there shall be added to the tax 5% of the amount of such tax if the failure is for not more than one month, with an additional 5% for each additional month or fraction thereof during which such failure continues, not exceeding 50% in the aggregate.
(Res. 1-2006, passed 4-11-2006)