§53.6694-2. Penalties for understatement due to an unreasonable position.
26 C.F.R. § 53.6694-2
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(a) of the Code in the manner stated in § 1.6694-2 of this chapter.
Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.
Notes, amendments, and revision history
Amendments
[T.D. 9436, 73 FR 78457, Dec. 22, 2008]
Source
Source: T.D. 7368, 40 FR 29843, July 16, 1975, unless otherwise noted. Redesignated by T.D. 8084, 51 FR 16303, May 2, 1986.
Authority
Authority: 26 U.S.C. 7805; 4960, unless otherwise noted. Section 53.6011-1 also issued under 26 U.S.C. 6011; Section 53.6060-1 also issued under 26 U.S.C. 6060(a); Section 53.6081-1 also issued under 26 U.S.C. 6081(a); Section 53.6109-1 also issued under 26 U.S.C. 6109(a); Section 53.6109-2 also issued under 26 U.S.C. 6109(a); Section 53.6695-1 also issued under 26 U.S.C. 6695(b).
Amendments
[T.D. 9436, 73 FR 78457, Dec. 22, 2008]