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of the reclassified physicians. The tax liability of each of the
reclassified physicians would likewise be affected.
We repeat that respondent correctly states that timely
filing of returns is required throughout the Internal Revenue
Code. This includes Forms 1096 and 1099. The consequences of
“Failure to Comply with Certain Information Reporting
Requirements” are contained in sections 6721 through 6724.
Section 6721(a) deals with “Failure to file correct information
returns”, which includes Forms 1096 and 1099 (see section 6041A),
and section 6721(a)(2)(A) describes a failure to file subject to
penalty as “any failure to file an information return with the
Secretary on or before the required filing date.” Section
6721(e) prescribes a “Penalty in case of intentional disregard”.
Section 6722 provides for similar penalties in the case of
“Failure to furnish correct payee statements”; section 6723
prescribes a penalty for “Failure to comply with other
information reporting requirements”, and section 6724 contains,
among other things, a reasonable cause waiver.
Nothing in the language or legislative history of section
530 leads us to the conclusion that denial of section 530 relief
was meant to be an additional penalty for the failure to timely
file information returns, particularly under the circumstances in
this case. Rather, as discussed above, section 530 was enacted
to protect taxpayers from having to litigate the status of
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