§6707A. Penalty for failure to include reportable transaction information with return — Inbound Citations
26 U.S.C. § 6707A
Cited by 9 provisions in release 119-102.
Citations to §6707A(c)
-
(2) The term “reportable transaction” has the meaning given to such term by section 6707A(c).
-
(a) Each material advisor (as defined in section 6111) with respect to any reportable transaction (as defined in section 6707A(c)) shall (whether or not required to file a return under section 6111 with respect to such transaction) maintain (in such manner as the Secretary may by regulations prescribe) a list—(1) identifying each person with respect to whom such advisor acted as a material advisor with respect to such transaction, and(2) containing such other information as the Secretary may by regulations require.
-
(d) For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).
-
(d) For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).
Citations to §6707A(c)(1)
-
(C) The term “prohibited reportable transaction” means any confidential transaction or any transaction with contractual protection (as defined under regulations prescribed by the Secretary) which is a reportable transaction (as defined in section 6707A(c)(1)).
Citations to §6707A(c)(2)
-
(B) The term “listed transaction” has the meaning given such term by section 6707A(c)(2).
-
(10) If a taxpayer fails to include on any return or statement for any taxable year any information with respect to a listed transaction (as defined in section 6707A(c)(2)) which is required under section 6011 to be included with such return or statement, the time for assessment of any tax imposed by this title with respect to such transaction shall not expire before the date which is 1 year after the earlier of—(A) the date on which the Secretary is furnished the information so required, or(B) the date that a material advisor meets the requirements of section 6112 with respect to a request by the Secretary under section 6112(b) relating to such transaction with respect to such taxpayer.
Citations to §6707A(d)
-
(3) Paragraph (1) shall not apply to any reportable transaction understatement unless—(A) the relevant facts affecting the tax treatment of the item are adequately disclosed in accordance with the regulations prescribed under section 6011,(B) there is or was substantial authority for such treatment, and(C) the taxpayer reasonably believed that such treatment was more likely than not the proper treatment.A taxpayer failing to adequately disclose in accordance with section 6011 shall be treated as meeting the requirements of subparagraph (A) if the penalty for such failure was rescinded under section 6707A(d).
-
(c) The provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply to any penalty imposed under this section.