(1) To transmit the new IRM 20.1.13, Penalty Handbook, Material Advisor and Reportable Transactions Penalties.
(1) IRM 20.1.13.2 incorporates content moved from IRM 20.1.6.16 regarding Failure to Furnish Information Regarding Reportable Transactions - IRC 6707. The content was reorganized for clarity.
(2) IRM 20.1.13.3 incorporates content moved from IRM 4.32.4 regarding IRC 6707A Penalty for Failure to Include Reportable Transaction Information With Return. Updated content with current procedures and eliminated obsolete instructions. Replaced templates with citations for applicable forms and letters.
(3) IRM 20.1.13.3 incorporates Interim Guidance Memorandum SBSE-04-0322-0009, Interim Guidance for IRC 6707A Penalty Approval, issued March 31, 2022 eliminating the penalty approval process beyond the immediate supervisor.
(4) IRM 20.1.13.4 incorporates content moved from IRM 20.1.6.18 regarding Failure to Maintain Lists of Advisees With Respect to Reportable Transactions - IRC 6708. The content was reorganized for clarity.
(5) IRM 20.1.13.5 incorporates content moved from IRM 20.1.6.15 regarding Actions to Enjoin Specified Conduct Related to Tax Shelters and Reportable Transactions - IRC 7408. The content was reorganized for clarity.
(6) Exhibit 20.1.13-1, Acronyms, defines abbreviations used this IRM.
This is a new IRM which will supersede IRM 4.32.4. IRM 4.32.4, dated 02-11-2016, will be made obsolete after the effective date of IRM 20.1.13. Content from IRM 20.1.6, dated 10-13-2021, has been incorporated and IRM 20.1.6 will be revised to eliminate duplicate content. This IRM incorporates Interim Guidance Memorandum SBSE-04-0322-0009, Interim Guidance for IRC 6707A Penalty Approval, dated 03-31-2022.
Nicole Young Scott
Acting Director, Business Support Office
Small Business/Self Employed