CHAPTER 68— ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES›Subchapter B— Assessable Penalties›PART I— GENERAL PROVISIONS
§ 6708. Failure to maintain lists of advisees with respect to reportable transactions
26 U.S.C. Subtitle F — Procedure and Administration (Internal Revenue Code) · 2026 edition · updated 2026-10-03 · United States
(a) Imposition of penalty
(1) In general
If any person who is required to maintain a list under section 6112(a) fails to make such list available upon written request to the Secretary in accordance with section 6112(b) within 20 business days after the date of such request, such person shall pay a penalty of $10,000 for each day of such failure after such 20th day.
(2) Reasonable cause exception
No penalty shall be imposed by paragraph (1) with respect to the failure on any day if such failure is due to reasonable cause.
(b) Penalty in addition to other penalties
The penalty imposed by this section shall be in addition to any other penalty provided by law.
(Added Pub. L. 98–369, div. A, title I, § 142(b), July 18, 1984, 98 Stat. 682; amended Pub. L. 99–514, title XV, § 1534(a), Oct. 22, 1986, 100 Stat. 2750; Pub. L. 108–357, title VIII, §§ 815(b)(5)(A), 817(a), Oct. 22, 2004, 118 Stat. 1583, 1584.)
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