SECTION 3. SCOPE

This revenue procedure applies to any person against whom a penalty under section 6707 or 6707A is assessed and who may also request rescission of all or a portion of the penalty from the Commissioner. A person may only request rescission of a penalty under section 6707 or 6707A if the violation relates to a reportable transaction other than a listed transaction. Further guidance will be issued providing preassessment administrative appeal rights to persons against whom the IRS proposes to assess a penalty under section 6707 or 6707A.