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§ 25.6694-4 - 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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In general. For rules for the extension of period of collection when a tax return preparer who prepared a return or claim for refund for gift tax under chapter 12 of subtitle B of the Internal Revenue Code pays 15 percent of a penalty for understatement of taxpayer's liability, and procedural matters relating to the investigation, assessment and collection of the penalties under section 6694(a) and (b), the rules under § 1.6694-4 of this chapter will apply.

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

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§ 25.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct.
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§ 25.6695-1 - Other assessable penalties with respect to the preparation of tax returns for other persons.