subsection (a) with respect to the taxpayer for such taxable year (without regard to paragraph (1) of this subsection). (3) Taxpayers subject to recapture (A) Fraud or reckless or intentional disregard of rules and regulations A taxpayer is described in this paragraph with respect to any taxable year if the Secretary determines that the amount described in paragraph (2)(A) with respect to the taxpayer for such taxable year was determined on the basis of fraud or a reckless or intentional disregard of rules and regulations. (B) Understatement of income