Abusive tax avoidance transaction (ATAT) (ATAT)

Is defined as:

• Tax shelter as defined under Internal Revenue Code (IRC) Section 6662(d)(2)(C),
• Reportable transaction as defined under IRC Section 6707A(c)(1) that is not adequately disclosed in accordance with IRC Section 6664(d)(2)(A),
• Listed transaction as defined under IRC Section 6707A(c)(2),
• Gross misstatement within the meaning of IRC Section 6404(g)(2)(D), or
• Transaction to which the noneconomic substance transaction (NEST) penalty applies under Revenue and Taxation Code (RTC) section 19774.