(iii) Any amount of negative adjustments in the credit grouping remaining after application of paragraph (c)(2)(iii)(C)(1)(ii) of this section is applied to the portion of the imputed underpayment to which a penalty has been imposed at the next highest rate in ascending order of rate in accordance withparagraph (c)(2)(iii)of this section until no negative amount remains.


26 CFR § 301.6233(a)-1

Scoping language

Is this correct? or