Inaccuracies or omissions found in a declaration or deed involving the indication of items to be retained for the assessment or liquidation of tax, as well as the restitution of a tax claim the payment of which has been unduly obtained from the State, entail the application of a surcharge of:
a. 40% in the case of deliberate failure to comply;
b. 80% in the case of abuse of rights within the meaning of the article L. 64 du livre des procédures fiscales ; it is reduced to 40% where it is not established that the taxpayer had the main initiative for the act or acts constituting the abuse of rights or was the main beneficiary;
c. 80% in the case of fraudulent manoeuvres or concealment of part of the price stipulated in a contract or in the case of application of article 792 bis.