Failure to furnish information regarding reportable transactions

If a person who is required to file a return under section 6111(a) with respect to any reportable transaction— Except as provided in paragraph (2), the penalty imposed under subsection (a) with respect to any failure shall be $50,000. The penalty imposed under subsection (a) with respect to any listed transaction shall be an amount equal to the greater of— The provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply to any penalty imposed under this section. For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).