26 U.S.C. § 6725

(a) In general In the case of each failure described in subsection (b) by any person with respect to a vessel or facility, such person shall pay a penalty of $10,000 in addition to the tax (if any). (b) Failures subject to penalty For purposes of subsection (a), the failures described in this subsection are— (1) any failure to make a report under section 4101(d) on or before the date prescribed therefor, and (2) any failure to include all of the information required to be shown on such report or the inclusion of incorrect information. (c) Reasonable cause exception No penalty shall be imposed under this section with respect to any failure if it is shown that such failure is due to reasonable cause.