N.Y. TAX Law § 992

§ 992. Addition to tax in the case of valuation understatement. In the\ncase of any underpayment of a tax imposed by this article which is\nattributable to a valuation understatement, there shall be added to the\ntax an amount equal to the applicable percentage of the underpayment so\nattributed.\n (a) For purposes of this section, the applicable percentage shall be\ndetermined under the following table:\n If the valuation claimed is\n the following percent of the The applicable\n correct valuation: percentage is:\n fifty percent or more but\n not more than sixty-six\n and two-thirds percent .................... ten\n forty percent or more but\n less than fifty percent ................... twenty\n less than forty percent ................... thirty\n (b) For purposes of this section, there is a valuation understatement\nif the claimed value of any property is sixty-six and two-thirds percent\nor less of the amount determined to be the correct amount of such\nvaluation.\n (c) This section shall not apply if the underpayment is less than one\nthousand dollars with respect to the estate of the decedent.\n (d) The commissioner may waive all or any part of the addition to tax\nprovided by this section on showing by the executor that there was a\nreasonable basis for the claimed valuation and that such claim was made\nin good faith.\n