IRS Reg-160868-04 (RIN 1545-BF61) appears to mix references to IRC Section 6011, which deals
mostly with electronic filing and general requirements for filing, and Treasury Regulation 1.6011,
which deals with requirements for reporting tax shelters and specific classes of reportable
sheltering transactions, which appears to be the intended reference.
As written, I was very confused - I believe the IRC Section 6011 references should be changed to
Reg 1.6011, or reference the actual IRC section(s) such as IRC 6707 that deal with reportable
transactions and shelters, not the most generic reporting requirements section (IRC 6011).
As written, would potentially impose $10,000 to $100,000 penalties on individuals for even
unintentionally omitting ANY information on ANY type of return, regardless of whether it involved a
reportable transaction or tax shelter, which is the obvious intended target of this regulation.
Comment on FR Doc # E8-21158
This is comment on Proposed Rule
Section 6707A and the Failure To Include on Any Return or Statement Any Information Required To Be Disclosed Under Section 6011 With Respect to a Reportable Transaction
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Related Comments
Public Submission Posted: 09/30/2008 ID: IRS-2008-0097-0003
Dec 10,2008 11:59 PM ET