Are there not constitutional issues to be realized when:
The penalties are vastly disproportionate to the sums in dispute.
There are even penalties issued in cases of legitimate disputes where no other noticeable loss or damage is apparent.
What is the point in penalizing somebody to the benefit of a government agency? Generally, there is no any actual loss noted or experienced by entities of the government. The government does not have any right to punitive compensation, and seeking gain or profit or exculpation is not a function or necessity of governmental bureaucracies.
Rather than the government depending on a combined penalty system of (1) being paid the amount due in full, (2) being paid interest upon the amount due, (3) being paid additional penalties and fines, and (4) reimbursed court fees and costs (and as applicable costs associated with law enforcement actions), would not a system of being paid only (1) and (2) be more fundamentally justified? Being that citizens seeking due process and redress should be encouraged in all cases as the highest and most pertinent issue and employees of the government are going to be paid regardless, agree to jointly-pool their resources as needed, and are normally over-funded for a reason.