1. LawStack
  2. Title 26 - Internal Revenue
  3. Subchapter D - MISCELLANEOUS EXCISE TAXES
  4. Part 55 - EXCISE TAX ON REAL ESTATE INVESTMENT TRUSTS AND REGULATED INVESTMENT COMPANIES
  5. Subpart C - Procedure and Administration
  6. 26 CFR § 55.6694-3
26 CFR § 55.6694-3
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 tax under chapter 44 of subtitle D 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 78459, Dec. 22, 2008]

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§ 55.6694-2 Penalties for understatement due to an unreasonable position
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§ 55.6694-4 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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