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Federal regulations · Through 2026-08-25 · Newer source version available

26 CFR 26.6694-2: -2 Penalties for understatement due to an unreasonable position.

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Where this section sits in the code
  1. Title 26—Internal Revenue
  2. CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
  3. SUBCHAPTER B—ESTATE AND GIFT TAXES
  4. PART 26—GENERATION-SKIPPING TRANSFER TAX REGULATIONS UNDER THE TAX REFORM ACT OF 1986

(a) In general. A person who is a tax return preparer of any return or claim for refund of generation-skipping transfer tax under chapter 13 of subtitle B 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.

Collected 2026-08-27T02:25:11Z. Source file · JSON

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