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The penalty is equal to the tax evaded, not collected, or not accounted for and paid over. The term person includes: The penalty isn't imposed on any unpaid volunteer director or member of a board of trustees of an exempt organization if the unpaid volunteer serves solely in an honorary capacity, doesn't participate in the day-to-day or financial operations of the organization, and doesn't have actual knowledge of the failure on which the penalty is imposed. This exception doesn't apply if it results in no one being liable for the penalty.