Any taxpayer who has an existing installment payment agreement under Section 6832 as of the start of the amnesty program, and who does not participate in the amnesty program, may not be subject to the penalty imposed under Section 7074.
The legislature occasionally skips outline levels.
For example:
(3) A person may apply [...]
(4)(a) A person petitioning for relief [...]
In this example, (3), (4),
and (4)(a) are all outline levels, but
(4) was
omitted by its authors. It's only implied. This presents an
interesting challenge when laying out the text. We've
decided to display a blank section with this note, in order
to aide readability.