Which of the following is a true statement about both the IRC § 6662A and § 6662(b) understatement penalties?

- Both were created by congress in 2004 to fight tax abuse

- it is easier to establish a reasonable cause defense to the § 6662A penalty

- the two sections cannot be used to penalize the same position twice

- the § 6662(b) substantial understatement penalty is a greater penalty