While California’s current $26 billion budget crisis and recent legislative enactments, such as elective single factor sales and unitary credits,[1] have been the most prominent issues on the California tax front, two important and continuing penalty issues should not be overlooked. This article provides a brief update on the current status of both the 2004 so-called "amnesty interest penalty" and the 2008 underpayment penalty, both of which are imposed on a strict liability basis. Continuing, viable issues surround both penalties.