[IMGCAP(1)]The IRS is taking a “formalistic approach” in interpreting its own Section 6011 regulations on disclosing reportable transactions, but not following its own rules on which tax years to assess the Section 6707A penalty.
The IRS is still assessing penalties under Section 6707A of the Tax Code, the penalty provision applicable to failure to disclose Congress-enacted reportable transactions taken since tax year 2004.
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