I agree with WagerX – I think link penalties are a myth. Its not logical. My bet is Google reduces the relevance/benefit of the links if it feels they are not natural, but not penalise. After all, if you released an artcilcle/PR (example) that was indeed very interesting news, people could theoretically naturally link it quickly and if it was hot news, could pick up thousands overnight.
That said, Google might penalise you if all those links appeared in “bad neighbourhoods” – possibly. But I still think it would simply discount them rather than penalise.