This revenue procedure provides
guidance to persons who are assessed a penalty under section 6707A
or 6707 of the Internal Revenue Code, and who may request
rescission of those penalties from the Commissioner.
The publication of this
revenue procedure sets forth new guidance for persons on whom a
penalty under section 6707A or 6707 of the Internal Revenue Code is
assessed, and who may request rescission of those penalties from
the Commissioner if the violation is with respect to a reportable
transaction other than a listed transaction. It is necessary to
alert taxpayers as soon as possible to these procedures because
section 6707A is effective for returns and statements the due date
for which is after October 22, 2004 and, section 6707, as amended,
is effective for returns the due date for which is after October
22, 2004; thus, these code sections are already effective and
taxpayers need guidance on rescission before the Service may assess
the penalty under section 6707A or 6707.
Matthew Cooper 202 622-4940
matthew.s.cooper@irscounsel.treas.gov
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.