The Internal Revenue Service

The Internal Revenue Service is offering an amnesty deal to firms that made and sold questionable tax shelters. In recent years the I.R.S. has extended similar offers to wealthy investors, but this is the first of its kind to firms that promote tax shelters.

Questionable shelters have been sold to thousands of wealthy investors in recent years. Therefore, the I.R.S. expects to bring in several billion dollars through the offer once the program is completed later this year.

Tax shelters typically require an accounting firm to design and sell the shelter, a law firm to write legal opinions approving the transactions and a bank or investment firm to carry out the financial workings.

The offer is being made to any type of firm that has created and sold tax shelters that the I.R.S. considers phony, as well as to firms that carried out the financial transactions that support such shelters.

Under the offer, the firms must disclose the names of the investors. Yet, it offers to assess no penalties against the firms for failing to provide information about investors earlier. Another advantage of the offer is that the agency will not disclose publicly the names of firms that come forward or the terms of their settlements.

Other penalties will still apply and firms that do not come forward face larger fines. Additionally, the I.R.S. reserves the right to refer to its own criminal division or to the Justice Department for criminal prosecution any employees from firms that received amnesty whom it suspects of having broken the law.