§ 28.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
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Verbatim text below is from the Electronic Code of Federal Regulations (eCFR), a public-domain U.S. government work. Always verify the current version with the eCFR before relying on it for any legal matter.
Full Text
In general.(a) 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(b) of the Code in the manner stated in § 1.6694-3 of this chapter.
Applicability date.(b) This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.
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