26 U.S.C. § 6707
§ 6707. Failure to furnish information regarding reportable transactions
No plain-English explainer yet. Below is the official text. Explainers are being added section by section.
History
Added in 1984 by the Deficit Reduction Act of 1984. Last changed October 22, 2004 by the American Jobs Creation Act of 2004.
Every change, newest first (4)
- October 22, 2004American Jobs Creation Act of 2004
- August 5, 1997Taxpayer Relief Act of 1997
- October 22, 1986Tax Reform Act of 1986
- July 18, 1984Deficit Reduction Act of 1984 · added this section
The law as written
Current through Public Law 119-102. Amendment notes omitted.
Structure
If a person who is required to file a return under section 6111(a) with respect to any reportable transaction—
fails to file such return on or before the date prescribed therefor, or
files false or incomplete information with the Secretary with respect to such transaction,
such person shall pay a penalty with respect to such return in the amount determined under subsection (b).
Except as provided in paragraph (2), the penalty imposed under subsection (a) with respect to any failure shall be $50,000.
The penalty imposed under subsection (a) with respect to any listed transaction shall be an amount equal to the greater of—
$200,000, or
50 percent of the gross income derived by such person with respect to aid, assistance, or advice which is provided with respect to the listed transaction before the date the return is filed under section 6111.
Subparagraph (B) shall be applied by substituting “75 percent” for “50 percent” in the case of an intentional failure or act described in subsection (a).
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).