26 U.S. Code § 6707 - Failure to furnish information regarding reportable transactions
Except as provided in paragraph (2), the penalty imposed under subsection (a) with respect to any failure shall be $50,000.
The provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply to any penalty imposed under this section.
For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).
2004—Pub. L. 108–357 amended section catchline and text generally, substituting provisions relating to penalty for failure to furnish information regarding reportable transactions for provisions relating to penalty for failure to furnish information regarding tax shelters.
1997—Subsec. (a)(1). Pub. L. 105–34, § 1028(d)(2), which directed the substitution of “paragraph (2) or (3), as the case may be” for “paragraph (2)” in subpar. (A) of par. (1), was executed by making the substitution in the concluding provisions of par. (1) to reflect the probable intent of Congress.
Subsec. (a)(2). Pub. L. 105–34, § 1028(d)(1), substituted “Except as provided in paragraph (3), the penalty” for “The penalty”.
Subsec. (a)(3). Pub. L. 105–34, § 1028(b), added par. (3).
1986—Subsec. (a)(2). Pub. L. 99–514, § 1532(a), amended par. (2) generally. Prior to amendment, par. (2) read as follows: “The penalty imposed under paragraph (1) with respect to any tax shelter shall be an amount equal to the greater of—
“(A) $500, or
“(B) the lesser of (i) 1 percent of the aggregate amount invested in such tax shelter, or (ii) $10,000.
The $10,000 limitation in subparagraph (B) shall not apply where there is an intentional disregard of the requirements of section 6111(a).”
Subsec. (b)(2). Pub. L. 99–514, § 1533(a), substituted “$250” for “$50”.
Amendment by Pub. L. 105–34 applicable to any tax shelter, as defined in section 6111(d) of this title, interests in which are offered to potential participants after Secretary of the Treasury prescribes guidance with respect to meeting requirements added by amendments made by Pub. L. 105–34, § 1028, see section 1028(e) of Pub. L. 105–34, set out as a note under section 6111 of this title.
Written determinations for this section
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