SECTION 2. CHANGES FROM REV.

PROC. 2020-54

The background section has been changed to state that the section 6662 penalty rate is generally 20 percent. The addition of “generally” acknowledges that the penalty rate is higher in some circumstances, although this revenue procedure does not apply in those circumstances. In addition, editorial changes have been made throughout this revenue procedure. Changes have been made in order to update the taxable years to which this revenue procedure applies. No substantive changes have been made.