§55.6694-2. Penalties for understatement due to an unreasonable position.
26 C.F.R. § 55.6694-2
In general. A person who is a tax return preparer of any return or claim for refund of excise tax under chapter 44 of subtitle D 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 78459, Dec. 22, 2008]
Source
Source: T.D. 7767, 46 FR 11282, Feb. 6, 1981; 46 FR 15263, Mar. 5, 1981, unless otherwise noted. Redesignated by T.D. 8180, 53 FR 6148, Mar. 1, 1988.
Authority
Authority: 26 U.S.C. 6001, 6011, 6071, 6091, and 7805. Section 55.6011-1 also issued under 26 U.S.C. 6011(a); Section 55.6060-1 also issued under 26 U.S.C. 6060(a); Section 55.6071-1 also issued under 26 U.S.C. 6071(a); Section 55.6081-1 also issued under 26 U.S.C. 6081(a); Section 55.6091-1 also issued under 26 U.S.C. 6091(a); Section 55.6109-1 also issued under 26 U.S.C. 6109(a); Section 55.6109-2 also issued under 26 U.S.C. 6109(a); Section 55.6151-1 also issued under 26 U.S.C. 6151; Section 55.6695-1 also issued under 26 U.S.C. 6695(b).
Source
Source: T.D. 7767, 46 FR 11282, Feb. 6, 1981; 46 FR 15263, Mar. 5, 1981, unless otherwise noted.
Amendments
[T.D. 9436, 73 FR 78459, Dec. 22, 2008]