26 CFR 28.6694-2
§ 28.6694-2 Penalties for understatement due to an unreasonable position.
United States · 26 CFR — Internal Revenue · Status: effective
Cite this
- Citation
- 26 CFR 28.6694-2, § 28.6694-2 Penalties for understatement due to an unreasonable position, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/112911
- Permanent ID
ys:prov:112911@1- SHA-256
a85c08ec31d32ac3013ab51b46aef721c254fac1bb2d2d693bbd2c3ff5d15cd7
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 any section 2801 tax is subject to penalties under section 6694(a) of the Code in the manner stated in § 1.6694-2 of this chapter.
(b) Applicability date. This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.
Legislative history
This is a federal regulation, adopted through agency rulemaking under the Administrative Procedure Act — not enacted by a recorded vote of Congress.