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Code of Federal Regulations (Last Updated: May 6, 2024) |
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Title 26 - Internal Revenue |
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Chapter I - Internal Revenue Service, Department of the Treasury |
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SubChapter D - Miscellaneous Excise Taxes |
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Part 53 - Foundation and Similar Excise Taxes |
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Subpart L - Procedure and Administration |
§ 53.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct.
Latest version.
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§ 53.6694-3 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 tax under Chapter 42 of the Internal Revenue Code (Code) shall be subject to penalties under section 6694(b) of the Code 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 78457, Dec. 22, 2008]