nondisclosed noneconomic substance transaction

(2) Nondisclosed noneconomic substance transactions For purposes of this subsection, the term “nondisclosed noneconomic substance transaction” means any portion of a transaction described in subsection (b)(6) with respect to which the relevant facts affecting the tax treatment are not adequately disclosed in the return nor in a statement attached to the return.

Source

26 USC § 6662(i)(2)


Scoping language

For purposes of this subsection
Is this correct? or