Today the IRS released final regulations relating to the penalty under section 6708 for failing to make available lists of advisees with respect to reportable transactions.  Section 6708 imposes a penalty upon material advisors for failing to make available, upon written request, the list required to be maintained by section 6112 within 20 business days after the date of such request.  The final regulations adopt, with some changes, proposed regulations issued on March 8, 2013.