The following excerpt is from Little v. C.I.R., 106 F.3d 1445 (9th Cir. 1997):
However, the additions to tax for negligence and for substantial understatement of tax do not violate the excessive fines clause of the Eighth Amendment. The Eighth Amendment provides that "[e]xcessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted." The Eighth Amendment limits the government's power to punish. Austin v. United States, 509 U.S. at 608-10, 113 S.Ct. at 2805.
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