(a) The comptroller has discretion to settle penalty
or interest on a tax liability if the comptroller determines that
the taxpayer exercised reasonable diligence to comply with the tax
laws of this state. In determining whether a taxpayer has exercised
reasonable diligence to comply with the tax laws of this state, the
Audit Division and Revenue Accounting Division will consider the factors
set out in subsections (b) and (c), respectively.