The IRS issued proposed regulations governing the penalty for failure of material advisers to provide lists of advisees in reportable transactions, which applies if the advisers do not supply the lists to the IRS within 20 business days after a written request.
Source: http://feedproxy.google.com/~r/AICPA_TaxAdvisor/~3/7QE4GPF75qw/20130307.aspx
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