Amends the Internal Revenue Code to modify provisions relating to the waiver of penalties for failure to disclose reportable transactions (i.e., transactions which have a potential for tax avoidance or evasion) to grant authority to the Secretary of the Treasury (instead of the Commissioner of Internal Revenue) to rescind or waive all or a portion of such penalties and to allow a waiver if there was reasonable cause for the failure to disclose such transactions and the taxpayer acted in good faith.