GroundRules
26 CFR 28.6694-2: -2 Penalties for understatement due to an unreasonable position.
Where this section sits in the code
- Title 26—Internal Revenue
- CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
- SUBCHAPTER B—ESTATE AND GIFT TAXES
- PART 28—IMPOSITION OF TAX ON GIFTS AND BEQUESTS FROM COVERED EXPATRIATES
(a) In general. A person who is a tax return preparer of any return or claim for refund of any section 2801 tax is subject to penalties under section 6694(a) of the Code in the manner stated in § 1.6694-2 of this chapter.
(b) Applicability date. This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.
Collected 2026-08-27T02:25:11Z. Source file · JSON