26 CFR 53.6694-2 - Penalties for understatement due to an unreasonable position.

Regulations last checked for updates: Oct 17, 2024

Title 26 - Internal Revenue last revised: Oct 10, 2024

View all text of Subpart L [§ 53.6001-1 - § 53.7701-1]

§ 53.6694-2 - Penalties for understatement due to an unreasonable position.

(a) In general. A person who is a tax return preparer of any return or claim for refund of tax under Chapter 42 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 78457, Dec. 22, 2008]

authority: 26 U.S.C. 7805; 4960, unless otherwise noted

cite as: 26 CFR 53.6694-2