On Friday, the IRS released an advance copy of Rev. Proc. 2007-25, 2007-12 I.R.B. ___ (3/19/07), which clarifies the rules for disclosing tax shelter penalties in SEC filings:
This revenue procedure amplifies Rev. Proc. 2005–51, 2005–2 C.B. 296, which provides guidance to persons who may be required to pay certain penalties under §§ 6662(h), 6662A, or 6707A, and who may be required under § 6707A(e) to disclose those penalties on reports filed with the SEC.



