The commissioner shall abate any penalty or addition to tax attributable to erroneous advice furnished to the taxpayer in writing by a representative of the department acting in such representative's official capacity. The provision shall apply only if: I. The written advice was reasonably relied upon by the taxpayer and was in response to a specific written request of the taxpayer; and II. The portion of the penalty or addition to tax did not result from a failure by the taxpayer to provide adequate or accurate information.
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