(1) If a taxpayer fails to report to the Department of Revenue a reportable transaction as required by ORS 314.308, there shall be added to the tax liability of the taxpayer for the tax year a penalty as follows:
(a) Individual taxpayers, $3,300.
(b) Corporation taxpayers, $16,700.
(2) If the reportable transaction is a listed transaction, in lieu of the penalty provided in subsection (1) of this section, the penalty shall be as follows:
(a) Individual taxpayers, $33,000.
(b) Corporation taxpayers, $66,000.
(3) This section applies to tax years beginning on or after January 1, 2007.