§ 6112. Material advisors of reportable transactions must keep lists of advisees, etc.
(a)
In general
Each material advisor (as defined in section
6111) with respect to any reportable transaction (as defined in section
6707A
(c)) shall (whether or not required to file a return under section
6111 with respect to such transaction) maintain (in such manner as the Secretary may by regulations prescribe) a list—
(b)
Special rules
(1)
Availability for inspection; retention of information on list
Any person who is required to maintain a list under subsection (a) (or was required to maintain a list under subsection (a) as in effect before the enactment of the American Jobs Creation Act of 2004)—
(2)
Lists which would be required to be maintained by 2 or more persons
The Secretary may prescribe regulations which provide that, in cases in which 2 or more persons are required under subsection (a) to maintain the same list (or portion thereof), only 1 person shall be required to maintain such list (or portion).