PENALTY ON PROMOTERS OF TAX SHELTERS.

SEC. 818. PENALTY ON PROMOTERS OF TAX SHELTERS.(a) Penalty on Promoting Abusive Tax Shelters.—Section 6700(a) is amended by adding at the end the following new sentence: “Notwithstanding the first sentence, if an activity with respect to which a penalty imposed under this subsection involves a statement described in paragraph (2)(A), the amount of the penalty shall be equal to 50 percent of the gross income derived (or to be derived) from such activity by the person on which the penalty is imposed.”.(b) Effective Date.—The amendment made by this section shall apply to activities after the date of the enactment of this Act.