26 CFR 25.6694-3
§ 25.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
United States · 26 CFR — Internal Revenue · Status: effective
Cite this
- Citation
- 26 CFR 25.6694-3, § 25.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/112840
- Permanent ID
ys:prov:112840@1- SHA-256
3725d21b3dbe2988b7fd2a95cfd62fde5ed0343e13b2781e82d91f8ae94419f5
The hash is SHA-256 of this version's text, with every run of whitespace collapsed to a single space and the ends trimmed. The ID always leads back here, and checking it says whether the text you cited is still the current version.
Full text
(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(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.
Legislative history
This is a federal regulation, adopted through agency rulemaking under the Administrative Procedure Act — not enacted by a recorded vote of Congress.