§28.6694-2. Penalties for understatement due to an unreasonable position.
26 C.F.R. § 28.6694-2
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.
Applicability date. This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.
Notes, amendments, and revision history
Source
Source: 90 FR 3395, Jan. 14, 2025, unless otherwise noted.
Authority
Authority: 26 U.S.C. 7805. Section 28.2801-0 through 28.2801-7 also issued under 26 U.S.C. 2801. Section 28.6001-1 also issued under 26 U.S.C. 6001. Section 28.6011(a)-1 also issued under 26 U.S.C. 6011 and 6011(a). Section 28.6060-1 also issued under 26 U.S.C. 6060 and 6060(a). Section 28.6071(a)-1 also issued under 26 U.S.C. 6071 and 6071(a). Section 28.6081-1 also issued under 26 U.S.C. 6081 and 6081(a). Section 28.6091-1 also issued under 26 U.S.C. 6091 and 6091(a). Section 28.6101-1 also issued under 26 U.S.C. 6101. Section 28.6107-1 also issued under 26 U.S.C. 6107 and 6107(c). Section 28.6109-1 also issued under 26 U.S.C. 6109 and 6109(a). Section 28.6151-1 also issued under 26 U.S.C. 6151. Section 28.6694-1 through 28.6694-4 also issued under 26 U.S.C. 6694. Section 28.6695-1 also issued under 26 U.S.C. 6695. Section 28.6696-1 also issued under 26 U.S.C. 6696 and 6696(c). Section 28.7701-1 also issued under 26 U.S.C. 7701.