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Lodged Submissions MT 2008/D1 - Penalty relating to statements: meaning of reasonable care, recklessness and intentional disregard Joint Submission lodged 11 July 2008 MT 2008/D2 - Shortfall penalties: administrative penalty for taking a position that is not reasonably arguable Joint Submission lodged 11 July 2008 MT 2008/D3 - Shortfall penalties: voluntary disclosures Joint Submission lodged 11 July 2008