The U.S. IRS has published a practice unit on the Accuracy-Related Penalty on Understatements with Respect to Reportable Transactions. The process overview of the practice unit includes the following: Treasury Regulation 1.6011-4 requires taxpayer to disclose participation in a reportable transaction on their income tax return and, when applicable, with the IRS Office of Tax Shelter Analysis (OTSA). IRC 6662A of the Internal Revenue Code imposes an accuracy-related penalty on any reportable transaction understatement. The penalty is effective for tax years ending after October 22, 2004. The IRC 6662A penalty applies to the following: Any listed transaction, and Any other...