In the case of any underpayment of a tax imposed by this article which is attributable to a valuation understatement, there shall be added to the tax an amount equal to the applicable percentage of the underpayment so attributed.
- (a) For purposes of this section, the applicable percentage shall be determined under the following table: If the valuation claimed is the following percent of the The applicable correct valuation: percentage is: fifty percent or more but not more than sixty-six and two-thirds percent .................... ten forty percent or more but less than fifty percent ................... twenty less than forty percent ................... thirty
- (b) For purposes of this section, there is a valuation understatement if the claimed value of any property is sixty-six and two-thirds percent or less of the amount determined to be the correct amount of such valuation.
- (c) This section shall not apply if the underpayment is less than one thousand dollars with respect to the estate of the decedent.
- (d) The commissioner may waive all or any part of the addition to tax provided by this section on showing by the executor that there was a reasonable basis for the claimed valuation and that such claim was made in good faith.