Failure to file correct information returns

In the case of a failure described in paragraph (2) by any person with respect to an information return, such person shall pay a penalty of $250 for each return with respect to which such a failure occurs, but the total amount imposed on such person for all such failures during any calendar year shall not exceed $3,000,000. For purposes of paragraph (1), the failures described in this paragraph are— If any failure described in subsection (a)(2) is corrected on or before the day 30 days after the required filing date— If any failure described in subsection (a)(2) is corrected after the 30th day referred to in paragraph (1) but on or before August 1 of the calendar year in which the required filing date occurs— If— The number of information returns to which paragraph (1) applies for any calendar year shall not exceed the greater of— If, with respect to an information return filed with the Secretary— Subparagraph (A) shall not apply with respect to any incorrect dollar amount to the extent that such error relates to an amount with respect to which an election is made under section 6722(c)(3)(B). The Secretary may issue regulations to prevent the abuse of the safe harbor under this paragraph, including regulations providing that this paragraph shall not apply to the extent necessary to prevent any such abuse. If any person meets the gross receipts test of paragraph (2) with respect to any calendar year, with respect to failures during such calendar year— A person meets the gross receipts test of this paragraph for any calendar year if the average annual gross receipts of such person for the most recent 3 taxable years ending before such calendar year do not exceed $5,000,000. For purposes of subparagraph (A), the rules of paragraphs (2) and (3) of section 448(c) shall apply. If 1 or more failures described in subsection (a)(2) are due to intentional disregard of the filing requirement (or the correct information reporting requirement), then, with respect to each such failure— the penalty imposed under subsection (a) shall be $500, or, if greater— in the case of a return required to be filed under section 6050I(a) with respect to any transaction (or related transactions), the greater of— in the case of any penalty determined under paragraph (2)— In the case of any failure relating to a return required to be filed in a calendar year beginning after 2014, each of the dollar amounts under subsections (a), (b), (d) (other than paragraph (2)(A) thereof), and (e) shall be increased by an amount equal to such dollar amount multiplied by the cost-of-living adjustment determined under section 1(f)(3) for the calendar year determined by substituting “calendar year 2011” for “calendar year 2016” in subparagraph (A)(ii) thereof. If any amount adjusted under paragraph (1)—