{"data":{"id":"us/26-cfr-31.6694-2","jurisdiction":"us","citation":"26 CFR 31.6694-2","heading":"-2 Penalties for understatement due to an unreasonable position.","body":"(a) In general. A person who is a tax return preparer of any return or claim for refund of employment tax under chapters 21 through 25 of subtitle C 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.\n(b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.","path":["Title 26—Internal Revenue","CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY","SUBCHAPTER C—EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE","PART 31—EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE","Subpart G—Administrative Provisions of Special Application to Employment Taxes (Selected Provisions of Subtitle F, Internal Revenue Code of 1954)"],"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":"52359cabfbd73dd79f28c4b2729a119116539e4359780cc060d064d124020329","source_id":"us-cfr","stale":true,"prev":"us/26-cfr-31.6694-1","next":"us/26-cfr-31.6694-3"},"notice":"GroundRules: Original legal text. Not legal advice."}