Failure to keep records necessary to meet reporting requirements under section 6047(d)

26 U.S.C. § 6704
in effect
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(a) Liability for penaltyAny person who—(1) has a duty to report or may have a duty to report any information under section 6047(d), and (2) fails to keep such records as may be required by regulations prescribed under section 6047(d) for the purpose of providing the necessary data base for either current reporting or future reporting, shall pay a penalty for each calendar year for which there is any failure to keep such records. (b) Amount of penalty(1) In generalThe penalty of any person for any calendar year shall be $50, multiplied by the number of individuals with respect to whom such failure occurs in such year. (2) Maximum amountThe penalty under this section of any person for any calendar year shall not exceed $50,000. (c) Exceptions(1) Reasonable causeNo penalty shall be imposed by this section on any person for any failure which is shown to be due to reasonable cause and not to willful neglect. (2) Inability to correct previous failureNo penalty shall be imposed by this section on any failure by a person if such failure is attributable to a prior failure which has been penalized under this section and with respect to which the person has made all reasonable efforts to correct the failure. (3) Pre-1983 failuresNo penalty shall be imposed by this section on any person for any failure which is attributable to a failure occurring before January 1, 1983, if the person has made all reasonable efforts to correct such pre-1983 failure.