That is all simply fantastic, Jack, and I'm glad you posted that because I remember you also making a comment about not caring about articles written by some unproven source, that is if I may be so bold as to *retread* something you said. That statement of yours was in reference to an article by an attorney that was an expert in the area being discussed and published in the AICPA's JoA, but never mind that now because the information below is what is pertinent to the current discussion.
So,back to your post that references the penalties assessed under sec 6694, there is no need to make any interpretation about the "spirit of the law" here. If you've ever read that section, you should note that it ALL pertains to UNDERSTATEMENT of taxpayer's liability, and nowhere in it does it reference understatement of deductions. If you are unsure and would like to read it again or perhaps for the first time, here is a link to that section of the code: https://www.law.cornell.edu/uscode/text/26/6694