Eggers Corporation filed an amended Form $1120,$ claiming an additional $$400,000$ deduction for payments to a contractor for a prior tax year, in which a $21\%$ tax rate applied. The amended return was based on the entity's interpretation of a Regulation that defined deductible advance payment expenditures. The nature of Egger's activity with the contractor did not exactly fit the language of the Regulation. Nevertheless, because so much tax was at stake, Eggers's tax department decided yo clsim the deduction.

Eggers's tax department estimated that there was only a $15\%$ chance that Eggers's interpretation would stand up to a Tax Court review.

What is the amount of tax penalty that Eggers is risking by taking this position?