(4) See Boelter, Tax Penalties and Interest (West Group, 1998) (
hereinafter, "Tax Penalties"), [paragraph] 4-6.10, for a discussion of the legislative history.
11 (2) (a), Convention Between the Government of the United States of America and the Government of the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (
hereinafter, "Indonesia Treaty") with a Related Protocol and Exchange of Notes Signed at Jakarta on the 11 th day of July, 1988 (
hereinafter, "Indonesia Protocol"), Art.