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Code · U.S. Code · Title 26 - INTERNAL REVENUE CODE · CHAPTER 68— ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES · Subchapter B— Assessable Penalties · § 6707

§ 6707. Failure to furnish information regarding reportable transactions

781 words·~4 min read·/usc/title-26/section-6707

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(a)In general If a person who is required to file a return under section 6111(a) with respect to any reportable transaction—
(1)fails to file such return on or before the date prescribed therefor, or
(2)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).
(b)Amount of penalty
(1)In general Except as provided in paragraph (2), the penalty imposed under subsection
(a)with respect to any failure shall be $50,000.
(2)Listed transactions The penalty imposed under subsection
(a)with respect to any listed transaction shall be an amount equal to the greater of—
(A)$200,000, or
(B)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).
(c)Rescission authority The provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply to any penalty imposed under this section.
(d)Reportable and listed transactions For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).
(Added Pub. L. 98–369, div. A, title I, § 141(b), July 18, 1984, 98 Stat. 680; amended Pub. L. 99–514, title XV, §§ 1532(a), 1533(a), Oct. 22, 1986, 100 Stat. 2750; Pub. L. 105–34, title X, § 1028(b), (d), Aug. 5, 1997, 111 Stat. 927, 928; Pub. L. 108–357, title VIII, § 816(a), Oct. 22, 2004, 118 Stat. 1583.)
Connections3 cite this · traces to 1
22 references not yet in our index
  • Pub. L. 98–369, div. A, title I, § 141(b)
  • 98 Stat. 680
  • Pub. L. 99–514, title XV
  • 100 Stat. 2750
  • Pub. L. 105–34, title X, § 1028(b)
  • 111 Stat. 927
  • Pub. L. 108–357, title VIII, § 816(a)
  • 118 Stat. 1583
  • Pub. L. 108–357
  • Pub. L. 105–34, § 1028(d)(2)
  • Pub. L. 105–34, § 1028(d)(1)
  • Pub. L. 105–34, § 1028(b)
  • Pub. L. 99–514, § 1532(a)
  • Pub. L. 99–514, § 1533(a)
  • Pub. L. 108–357, title VIII, § 816(c)
  • 118 Stat. 1584
  • Pub. L. 105–34
  • Pub. L. 105–34, § 1028
  • section 1028(e) of Pub. L. 105–34
  • Pub. L. 99–514, title XV, § 1532(b)
  • Pub. L. 99–514, title XV, § 1533(b)
  • section 141(d) of Pub. L. 98–369
Citation graph
cites case law
§ 6707
Failure to furnish information regarding reportable transactions
Stat.×2
U.S.C.×1
Pub. L.Pub. L. 98–369, div. A, title I, § 141(b)
Stat.98 Stat. 680
Pub. L.Pub. L. 99–514, title XV
Stat.100 Stat. 2750
Pub. L.Pub. L. 105–34, title X, § 1028(b)
Cites 23 · showing 6Cited by 3 across 2 sources
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