U.S. Code > Title 26 Internal Revenue Code > Subtitle F—Procedure and Administration (§§ 6001—7874) > CHAPTER 76—JUDICIAL PROCEEDINGS (§§ 7401—7491) > Subchapter A—Civil Actions by the United States (§§ 7401—7410) > § 7408. Actions to enjoin specified conduct related to tax shelters and reportable transactions

§ 7408. Actions to enjoin specified conduct related to tax shelters and reportable transactions

(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.
(d) Citizens and residents outside the United States
If any citizen or resident of the United States does not reside in, and does not have his principal place of business in, any United States judicial district, such citizen or resident shall be treated for purposes of this section as residing in the District of Columbia.