![]() |
Code of Federal Regulations (Last Updated: July 5, 2024) |
![]() |
Title 26 - Internal Revenue |
![]() |
Chapter I - Internal Revenue Service, Department of the Treasury |
![]() |
SubChapter B - Estate and Gift Taxes |
![]() |
Part 25 - Gift Tax; Gifts Made After December 31, 1954 |
![]() |
Procedure and Administration |
§ 25.6694-2 - Penalties for understatement due to an unreasonable position.
Latest version.
-
§ 25.6694-2 Penalties for understatement due to an unreasonable position.
(a) In general. A person who is a tax return preparer of any return or claim for refund of gift tax under chapter 12 of subtitle B 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.
(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 78451, Dec. 22, 2008]