The Administrative Procedure Act
The Internal Revenue Code (the “Code”) contains over one hundred different civil penalties for various acts or failures to act. For example, Section 6707A requires taxpayers, in certain instances, to report certain transactions that they have entered into, particularly those that the IRS has determined have the potential for tax avoidance or evasion.
These “reportable transactions” can generally be broken down in more subsets, one of which includes “listed transactions.” For these purposes, a “listed transaction” is one that is the same or substantially similar to one of the types of transactions that the IRS has determined to be a tax avoidance transaction identified by notice, regulation, or other form of published guidance as a listed transaction. Generally, listed transactions are reported on IRS Form 8886, Reportable Transaction Disclosure Statement.
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