§56.6694-2. Penalties for understatement due to an unreasonable position.
26 C.F.R. § 56.6694-2
In general. A person who is a tax return preparer of any return or claim for refund of excise tax under chapter 41 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 78460, Dec. 22, 2008]
Authority
Authority: 26 U.S.C. 7805. Section 56.4911-7 also issued under 26 U.S.C. 4911(f)(3); Section 56.6060-1 also issued under 26 U.S.C. 6060(a); Section 56.6109-1 also issued under 26 U.S.C. 6109(a); Section 56.6109-2 also issued under 26 U.S.C. 6109(a); Section 56.6695-1 also issued under 26 U.S.C. 6695(b).
Source
Source: T.D. 8308, 55 FR 35598, Aug. 31, 1990, unless otherwise noted.
Amendments
[T.D. 9436, 73 FR 78460, Dec. 22, 2008]