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Merill recently realized that she failed to report $20,000 of income on last year's last return. She is concerned that she may be subject to

Merill recently realized that she failed to report $20,000 of income on last year's last return. She is concerned that she may be subject to a substantial understatement penalty but is not sure how to determine this. Indicate the Internal Revenue Code section and subsection that provides the rules for the applicability of the substantial understatement penalty.

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