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How is the penalty computed where a single group return is filed using the combined report method?

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How is the penalty computed where a single group return is filed using the combined report method?

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The penalty for each taxpayer in the combined group is computed by determining each taxpayer’s understatement of tax, and then applying the 20 percent penalty to that amount. This is similar to the way the tax liability is computed when a single group return is filed using the combined report method. The penalty liabilities of the electing group members are then aggregated and reported on a group basis.

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