Seller

For purposes of the list maintenance requirement, a seller is:

1. Any organizer, underwriter, broker, or dealer (or other similar person) who transfers any interest in a tax shelter.
2. Any agent who negotiates the transfer of any interest in a tax shelter for the tax shelter, an organizer, or other person described in (1).
3. Any investor (not described in (1)) who transfers any interest in a tax shelter, or
4. Any other person who receives consideration in connection with another person's right to participate in a tax shelter, for services necessary to the organization or structure of such tax shelter (other than services that do not constitute participation in the organization or management of a tax shelter under Treasury Regulation section 301.6111-1T), or for information that is integral to the participation in such tax shelter.