gross valuation misstatements

(2) Gross valuation misstatements The term “gross valuation misstatements” means— (A) any substantial valuation misstatement under chapter 1 as determined under subsection (e) by substituting— (i) in paragraph (1)(A), “200 percent” for “150 percent”, (ii) in paragraph (1)(B)(i)— (I) “400 percent” for “200 percent”, and (II) “25 percent” for “50 percent”, and (iii) in paragraph (1)(B)(ii)— (I) “$20,000,000” for “$5,000,000”, and (II) “20 percent” for “10 percent”. (B) any substantial overstatement of pension liabilities as determined under subsection (f) by substituting “400 percent” for “200 percent”, (C) any substantial estate or gift tax valuation understatement as determined under subsection (g) by substituting “40 percent” for “65 percent”, and (D) any disallowance of a deduction described in subsection (b)(10).

Source

26 USC § 6662(h)(2)

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Scoping language

None identified, default scope is assumed to be the parent (part II) of this section.

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