Tax Tip of the Day IRC Section 6707(a) imposes a penalty for failing to include on any return or statement any information about a reportable transaction that is required to be included with the return or statement. Reportable transactions are ones that the IRS has determined have a potential for tax avoidance or evasion. Sec. 6707(a) also prescribes a heightened penalty for listed transactions, which are reportable transactions that are the same as, or substantially similar to, certain transactions the IRS has identified as tax avoidance transactions. Moreover, Sec. 6707A(e) imposes a penalty for failure to disclose in required periodic reports to the SEC any penalty under Sec. 6707(a) a person is required to pay for a listed transaction; any penalty a person is required to pay under Sec. 6662(a) viz. accuracy-related penalty on understatement of tax for a reportable transaction; and any penalty under Sec. 6662(h) (increase in accuracy-related penalty in case of gross-valuation misstatements) for a reportable transaction.
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