LegalFix
Sign In

§ 156.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct.

Copy with citation
Copy as parenthetical citation

In general. A person who is a tax return preparer of any return or claim for refund of tax under section 5881 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.

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

Previous Section
§ 156.6694-2 - Penalties for understatement due to an unreasonable position.
Next Section
§ 156.6694-4 - 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.