Section 6.14. Enforcement concerning nondisclosed eligible tax liabilities

(a) The Department will not institute an administrative or judicial proceeding against a taxpayer with respect to an eligible tax liability that is disclosed on the tax amnesty return and paid during the amnesty period.

(b) The Department may impose penalties and pursue criminal action with respect to the difference between the amount disclosed on a tax amnesty return and the amount determined to be due by the Department subsequent to the amnesty period.

(c) The Department may institute civil or criminal proceedings against a taxpayer with respect to an amount of tax that is not disclosed on the tax amnesty return.