Internal Revenue Code 6677 clarification.

[Mach7]

I am positive that I read somewhere that the penalty for failure to file a form such as the 3520/3520a was 10k or 35% of the gross reportable amount, [b]and that the penalty could not exceed the total gross reportable amount.[/b]

For some reason i cannot find the clarification in the last sentence....did they recently change this??

In other words...can they penalize you 10k for a 100 dollar account if you did not file the appropriate paperwork??[/i]