§ 20.6694-2. Penalties for understatement due to an unreasonable position.
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/us/cfr/t26/s§ 20.6694-2·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
(a)In general. A person who is a tax return preparer of any return or claim for refund of estate tax under chapter 11 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]
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§ 20.6694-2
Penalties for understatement due to an unreasonable position.
Treas. Dec.T.D. 9436
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