To amend the Internal Revenue Code of 1986 to allow the Secretary of the Treasury to not impose a penalty for failure to disclose reportable transactions when there is reasonable cause for such failure, to modify such penalty, and for other purposes.

Amends the Internal Revenue Code to: (1) allow a waiver of the penalty for failure to disclose reportable transactions (i.e., transactions which have a potential for tax avoidance or evasion) if such failure is due to reasonable cause and not due to willful neglect; (2) revise the amount of the penalty for such failure; and (3) limit the imposition of such penalty to the taxpayer (currently, any person).

Reaffirms the authority of the Commissioner of Internal Revenue to rescind all or any portion of the penalty for failure to furnish information regarding reportable transactions.