§11312

transactions * * * should be punished at least as severely as one who does only the former." Superior Trading, LLC v. Commissioner, 728 F.3d at 682; see also Gilman v. Commissioner, 933 F.2d at 150. 4(...continued) Act of 1990, Pub. L. No. 101-508, sec. 11312, 104 Stat. at 1388-454 to 1388-455, Congress amended sec. 6662, changing, inter alia, the phrase "valuation overstatement" to refer to "valuation misstatement". - 8 - [*8] The minority view shared by the Courts ofAppeals for the Fifth and

ain property and claimed depreciation 191(...continued) 6659 and consolidated the various accuracy-related penalties into sec. 6662, carrying over the same essential language as sec. 6659. In the Omnibus Reconciliation Act of 1990, Pub. L. 101- 508, sec. 11312, 104 Stat. 1388-454 to 1388-455, Congress amended sec. 6662, changing, inter alia, the phrase “valuation overstatement” to refer to “valuation misstatement”. 192 Former sec. 6659(c), similar to current sec. 6662(e) and (h), provided: “ther