1. LawStack
  2. Title 26 - Internal Revenue
  3. Subchapter C - EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE
  4. Part 31 - EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE
  5. Subpart G - Administrative Provisions of Special Application to Employment Taxes (Selected Provisions of Subtitle F, Internal Revenue Code of 1954)
  6. 26 CFR § 31.6694-3
26 CFR § 31.6694-3
Penalty for understatement due to willful, reckless, or intentional conduct
June 25, 2020
CFR

(a) In general. A person who is a tax return preparer of any return or claim for refund of employment tax under chapters 21 through 25 of subtitle C of the Internal Revenue Code (Code) shall be subject to penalties under section 6694(b) of the Code in the manner stated in §1.6694-3 of this chapter.

(b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

[T.D. 9436, 73 FR 78454, Dec. 22, 2008, as amended by T.D. 9436, 74 FR 5105, Jan. 29, 2009]

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§ 31.6694-2 Penalties for understatement due to an unreasonable position
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§ 31.6694-4 Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters

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