26 CFR 53.6694-3: -3 Penalty for understatement due to willful, reckless, or intentional conduct.
Where this section sits in the code
- Title 26—Internal Revenue
- CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
- SUBCHAPTER D—MISCELLANEOUS EXCISE TAXES
- PART 53—FOUNDATION AND SIMILAR EXCISE TAXES
- Subpart L—Procedure and Administration
(a) In general. A person who is a tax return preparer of any return or claim for refund of tax under Chapter 42 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.
(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