26 CFR 31.6694-3
§ 31.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
United States · 26 CFR — Internal Revenue · Status: effective
Cite this
- Citation
- 26 CFR 31.6694-3, § 31.6694-3 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/113273
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Full text
(a) In general. A person who is a tax return preparer of any return or claim for refund of employment tax under chapters 21 through 25 of subtitle C 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.