65 percent
(2)The term “gross valuation misstatements” means— (A)any substantial valuation misstatement under chapter 1 as determined under subsection (e) by substituting— (i)in paragraph (1)(A), “200 percent” for “150 percent”, (ii)in paragraph (1)(B)(i)— (I)“400 percent” for “200 percent”, and (II)“25 percent” for “50 percent”, and (iii)in paragraph (1)(B)(ii)— (I)“$20,000,000” for “$5,000,000”, and (II)“20 percent” for “10 percent”. (B)any substantial overstatement of pension liabilities as determined under subsection (f) by substituting “400 percent” for “200 percent”, and (C)any substantial estate or gift tax valuation understatement as determined under subsection (g) by substituting “40 percent” for “65 percent”. (i)