REVENUE AND TAXATION CODE
SECTION 19778
19778. For any amended return filed after April 15, 2004, and
before the taxpayer is contacted by the Internal Revenue Service or
the Franchise Tax Board regarding a potentially abusive tax shelter,
then, for taxable years beginning after December 31, 1998, with
respect to any understatement of tax related to using reportable
transactions as defined in Section 18407, as added by the act adding
this section, the taxpayer is subject to interest as provided under
Section 19101 but at a rate of 150 percent of the adjusted annual
rate established under Section 19521.
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