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Okay... Cool. Now at least we understand where the point of disagreement is.

I don't mean to argue, I just believe this new tax is much more egregious than you believe it to be.

I came to my interpretation based on several things

1) the math, as I mentioned.
2) The fact that it is a called a surtax, not a penalty. (They could easily have just upped the underpayment tax penalties to accomplish something like your description).
3) Look at the PDF link I gave you again and read the last part under "Rationale". It says:
"In addition, since most taxpayers overpay their taxes each year through withholding, the surcharge would reduce taxpayer refunds (rather than require a larger final tax payment) in April, when final tax returns are due."
They apply the surcharge whether your taxes were paid in full, or not.

Am I missing something?