Any taxpayer who does not file the form under sub. (2) and who is required to file the form is subject to the following penalty: 1.
(1)#
If the taxpayer participated in a reportable transaction that is not a listed transaction, the lesser of $15,000 or 10 percent of the tax benefit obtained from the reportable transaction.
(2)#
If the taxpayer participated in a listed transaction, $30,000.