CCA 201101012
Penalty for Failure to Include Reportable Transaction Information with Return
ID: CCA_2010100613175426 Number: 201101012
Release Date: 1/7/2011
Office: ---
UILC: 6707A.00-00
From: ---
Sent: Wednesday, October 06, 2010 1:17:55 PM
To: ---
Cc: ---
Subject: RE: Section 6707A
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As long as the partnership had an obligation to disclose a listed or reportable transaction under section 6011 and the regulations, it is liable for the 6707A for failing to so disclose. You are correct that because a partnership is not a taxpaying entity there is no decrease in tax on which to compute the penalty.
Instead, the penalty will be the maximum penalty permitted by the new law.
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Source: view the official PDF
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