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SARS must remit an understatement penalty for a substantial understatement if an independentregistered tax practitioner issued a tax opinion prior to the date that the
SARS must remit an understatement penalty for a substantial understatement if an independentregistered tax practitioner issued a tax opinion prior to the date that the return is due andconcluded that it is strongly arguable that the taxpayers position will be upheld if the matterproceeds to court.
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