26 CFR 40.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct.

Regulations last checked for updates: May 02, 2025

Title 26 - Internal Revenue last revised: Feb 28, 2025

View all text of Part 40 [§ 40.0-1 - § 40.7701-1]

§ 40.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct.

(a) In general. A person who is a tax return preparer of any return or claim for refund of any tax to which this part 40 applies shall be subject to penalties under section 6694(b) in the manner stated in § 1.6694-3 of this chapter.

(b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

[T.D. 9436, 73 FR 78455, Dec. 22, 2008; 74 FR 5106, Jan. 29, 2009]

authority: 26 U.S.C. 7805.

source: T.D. 8442, 57 FR 48177, Oct. 22, 1992, unless otherwise noted.

cite as: 26 CFR 40.6694-3