{"data":{"id":"us/26-cfr-28.6694-3","jurisdiction":"us","citation":"26 CFR 28.6694-3","heading":"-3 Penalty for understatement due to willful, reckless, or intentional conduct.","body":"(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(b) of the Code in the manner stated in § 1.6694-3 of this chapter.\n(b) Applicability date. This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.","path":["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"],"source_url":"https://www.ecfr.gov/api/versioner/v1/full/2026-08-25/title-26.xml","current_through":"2026-08-25","vintage":"","retrieved_at":"2026-08-27T02:25:11Z","sha256":"59ec8d3cb74583fb350c1866a890f736c58df472bc231527bdd235816f3f1717","source_id":"us-cfr","stale":true,"prev":"us/26-cfr-28.6694-2","next":"us/26-cfr-28.6694-4"},"notice":"GroundRules: Original legal text. Not legal advice."}