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§ 41.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct.

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In general. A person who is a tax return preparer of any return or claim for refund of excise tax under section 4481 shall be subject to penalties under section 6694(b) 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.

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§ 41.6694-2 - Penalties for understatement due to an unreasonable position.
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§ 41.6694-4 - Extension of period of collection when preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.