§ 301.6708-1 Failure to maintain lists of advisees with respect to reportable transactions.§ 301.6708-1T Failure to maintain list of investors in potentially abusive tax shelters (temporary).
Amended 2004
- 2004 Pub. L. 108-357 Pub. L. 108–357, § 815(b)(5)(A), substituted “advisees with respect to reportable transactions” for “investors in potentially abusive tax shelters” in section catchline.
Final rules 1
(a) Imposition of penalty
Amended 1986, 2004
- 2004 Pub. L. 108-357 Pub. L. 108–357, § 817(a), amended heading and text of subsec. (a) generally. Prior to amendment, text read as follows: “Any person who fails to meet any requirement imposed by section 6112 shall pay a penalty of $50 for each person with respect to whom there is such a failure, unless it is shown that such failure is due to reasonable cause and not due to willful neglect. The maximum penalty imposed under this subsection for any calendar year shall not exceed $100,000.”
- 1986 Pub. L. 99-514 Pub. L. 99–514 substituted “$100,000” for “$50,000”.
(1) In general If any person who is required to maintain a list under section 6112(a) fails to make such list available upon written request to the Secretary in accordance with section 6112(b) within 20 business days after the date of such request, such person shall pay a penalty of $10,000 for each day of such failure after such 20th day.
Cited by 1
(2) Reasonable cause exception No penalty shall be imposed by paragraph (1) with respect to the failure on any day if such failure is due to reasonable cause.
(b) Penalty in addition to other penalties The penalty imposed by this section shall be in addition to any other penalty provided by law.