1. LawStack
  2. Title 26 - Internal Revenue
  3. Subchapter D - MISCELLANEOUS EXCISE TAXES
  4. Part 40 - EXCISE TAX PROCEDURAL REGULATIONS
  5. 26 CFR § 40.6694-3
26 CFR § 40.6694-3
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 any tax to which this part 40 applies shall be subject to penalties under section 6694(b) 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 78455, Dec. 22, 2008; 74 FR 5106, Jan. 29, 2009]

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§ 40.6694-2 Penalties for understatement due to an unreasonable position
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§ 40.6694-4 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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