Page:United States Statutes at Large Volume 100 Part 3.djvu/942

 100 STAT. 2750

PUBLIC LAW 99-514—OCT. 22, 1986

Internal Revenue Code of 1986 as amended by this section) interests in which are first offered for sale after December 31, 1986. SEC. 1532. INCREASED PENALTY SHELTERS.

FOR FAILURE TO REGISTER TAX

(a) IN GENERAL.—Paragraph (2) of section 6707(a) (relating to penalty for failure to register tax shelters) is amended to read as follows: "(2) AMOUNT OF PENALTY.—The penalty imposed under paragraph (1) with respect to any tax shelter shall be an amount "^^ equal to the greater of— "(A) 1 percent of the aggregate amount invested in such tax shelter, or "(B) $500." (b) EFFECTIVE DATE.—The amendment made by this section shall apply to failures with respect to tax shelters interests in which are first offered for sale after the date of the enactment of this Act. SEC. 1533. PENALTY FOR FAILURE TO INCLUDE TAX SHELTER IDENTIFICATION NUMBER ON RETURN INCREASED TO $250.

(a) IN GENERAL.—Paragraph (2) of section 67070t>) (relating to penalty for failure to furnish tax shelter identification number) is amended by striking out "$50" and inserting in lieu thereof "$250". (b) EFFECTIVE DATE.—The amendment made by this section shall apply to returns filed after the date of the enactment of this Act. SEC. 1534. INCREASED PENALTY FOR FAILURE TO MAINTAIN LISTS OF INVESTORS IN POTENTIALLY ABUSIVE TAX SHELTERS.

(a) IN GENERAL.—Subsection (a) of section 6708 (relating to failure to maintain lists of investors in potentially abusive tax shelters) is amended by striking out "$50,000" and inserting in lieu thereof "$100,000". (b) EFFECTIVE DATE.—The amendments made by this section shall apply to failures occurring or continuing after the date of the enactment of this Act. SEC. 1535. CLARIFICATION OF TREATMENT OF SHAM OR FRAUDULENT TRANSACTIONS UNDER SECTION 6621(c). (a) CLARIFICATION OF TREATMENT OF SHAM OR FRAUDULENT TRANS-

ACTIONS.—Subparagraph (A) of section 6621(c)(3) (as so redesignated) is amended by striking out "and" at the end of clause (iii), by striking out the period at the end of clause (iv) and inserting in lieu thereof ", and", and by adding at the end thereof the following new clause: "(v) any sham or fraudulent transaction." (b) EFFECTIVE DATE.—The amendment made by subsection (a) shall apply to interest accruing after December 31, 1984; except that such amendment shall not apply in the case of any underpayment with respect to which there wgis a final court decision before the date of the enactment of this Act.

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