SECTION 7. DRAFTING

INFORMATION

The principal author of this revenue procedure is Matthew S. Cooper of the Office of the Associate Chief Counsel (Procedure and Administration), Administrative Provisions & Judicial Practice Division. For further information regarding this revenue procedure, contact Matthew S. Cooper at (202) 622–4940 (not a toll-free call).

The collection of information in this revenue procedure is in section 4. This information is required to administer the provisions of sections 6707(c) and 6707A(d) and determine whether the Service should rescind penalties otherwise applicable. The likely respondents are taxpayers and material advisors who are subject to a penalty under section 6707 or 6707A. The estimated total annual reporting or recordkeeping burden is 3865.5 hours.

The estimated annual burden per respondent/recordkeeper varies from 3 to 6 hours, depending on individual circumstances, with an estimated average of 4.5 hours. The estimated number of respondents or recordkeepers is 859.

The estimated annual frequency of responses (used for reporting requirements only) is 1.

Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. § 6103.