| http://www.w3.org/ns/prov#value | - be made without regard to the rules of subsections (b), (c), and (d) of section 6664 of the Internal Revenue Code of 1986, and (B) if any such interest or applicable penalty is imposed, the amount of such interest or penalty shall be equal to twice that determined without regard to this section. (2) APPLICABLE TAXPAYER- For purposes of this subsection-- (A) IN GENERAL- The term `applicable taxpaye
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