(a) In General. The Secretary of the Department of Finance and Administration shall abate any portion of any penalty or addition to tax attributable to erroneous advice furnished to the taxpayer in writing by an agent of the secretary acting in such agent's official capacity.
(b) Limitations. The provisions of subsection (a) of this section shall apply only if:(1) The written advice was reasonably relied upon by the taxpayer and was in response to a specific written request of the taxpayer; and(2) The portion of the penalty or addition to tax did not result from a failure by the taxpayer to provide adequate or accurate information.
(1) The written advice was reasonably relied upon by the taxpayer and was in response to a specific written request of the taxpayer; and
(2) The portion of the penalty or addition to tax did not result from a failure by the taxpayer to provide adequate or accurate information.