MODIFICATION OF ACTIONS TO ENJOIN CERTAIN CONDUCT RELATED TO TAX SHELTERS AND REPORTABLE TRANSACTIONS.

SEC. 820. MODIFICATION OF ACTIONS TO ENJOIN CERTAIN CONDUCT RELATED TO TAX SHELTERS AND REPORTABLE TRANSACTIONS.(a) In General.—Section 7408 (relating to action to enjoin promoters of abusive tax shelters, etc.) is amended by redesignating subsection (c) as subsection (d) and by striking subsections (a) and (b) and inserting the following new subsections:“(a) Authority To Seek Injunction.—A civil action in the name of the United States to enjoin any person from further engaging in specified conduct may be commenced at the request of the Secretary. Any action under this section shall be brought in the district court of the United States for the district in which such person resides, has his principal place of business, or has engaged in specified conduct. The court may exercise its jurisdiction over such action (as provided in section 7402(a)) separate and apart from any other action brought by the United States against such person.“(b) Adjudication and Decree.—In any action under subsection (a), if the court finds—“(1) that the person has engaged in any specified conduct, and“(2) that injunctive relief is appropriate to prevent recurrence of such conduct,the court may enjoin such person from engaging in such conduct or in any other activity subject to penalty under this title.“(c) Specified Conduct.—For purposes of this section, the term ‘specified conduct’ means any action, or failure to take action, which is—“(1) subject to penalty under section 6700, 6701, 6707, or 6708, or “(2) in violation of any requirement under regulations issued under section 330 of title 31, United States Code.”.(b) Conforming Amendments.—(1) The heading for section 7408 is amended to read as follows:“SEC. 7408. ACTIONS TO ENJOIN SPECIFIED CONDUCT RELATED TO TAX SHELTERS AND REPORTABLE TRANSACTIONS.” .(2) The table of sections for subchapter A of chapter 76 is amended by striking the item relating to section 7408 and inserting the following new item: “Sec. 7408. Actions to enjoin specified conduct related to tax shelters and reportable transactions.”. (c) Effective Date.—The amendment made by this section shall take effect on the day after the date of the enactment of this Act.118 STAT. 1586