26 U.S.C. § 6707 — Failure to furnish information regarding reportable transactions

(a) In general If a person who is required to file a return under section 6111(a) about 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^* about such transaction, such person must pay a penalty about 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) about any failure must be $50,000. (2) Listed transactions The penalty imposed under subsection (a) about any listed transaction must be an amount equal to the greater of— (A) $200,000, or (B) 50 percent of the gross income derived by such person about aid, assistance, or advice which is provided about the listed transaction before the date the return is filed under section 6111. Subparagraph (B) must 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) must 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).