1. LawStack
  2. Title 26 - Internal Revenue
  3. Subchapter D - MISCELLANEOUS EXCISE TAXES
  4. Part 54 - PENSION EXCISE TAXES
  5. 26 CFR § 54.6694-2
26 CFR § 54.6694-2
Penalties for understatement due to an unreasonable position
June 25, 2020
CFR

(a) In general. A person who is a tax return preparer of any return or claim for refund of tax under Chapter 43 of subtitle D of the Internal Revenue Code (Code) shall be subject to penalties under section 6694(a) of the Code in the manner stated in §1.6694-2 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 78458, Dec. 22, 2008]

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§ 54.6694-1 Section 6694 penalties applicable to tax return preparer
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§ 54.6694-4 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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