Revenue Procedure 2007–21, 2007–1 C.B. 613, includes procedures for making a written request for rescission of a penalty imposed by either Internal Revenue Code section 6707 or section 6707A with respect to a reportable transaction that is not a listed transaction. A section 6707 penalty applies to a material advisor who is required to file a return (Material Advisor Disclosure Statement (Form 8918) or successor form) under section 6111(a) with respect to a reportable transaction and who fails to file a timely return or who files a return with false or incomplete information. A section 6707A penalty applies to any person who fails to include on any return or statement (Reportable Transaction Disclosure Statement (Form 8886) or successor form) any information required to be disclosed under section 6011 with respect to a reportable transaction.
The mailing address listed in Revenue Procedure 2007–21, 2007–1 C.B. 613, Section 4.08 has been changed, and the new address, effective immediately, is as follows:
Internal Revenue Service
Office of Tax Shelter Analysis
1973 North Rulon White Blvd
M/S 4916
Ogden, UT 84201
The principal author of this announcement is Gerald Semasek of the Office of Associate Chief Counsel (Procedure & Administration). For further information regarding this announcement, contact Gerald Semasek at (202) 317-6845 (not a toll-free number).
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