§ 28.6694-4. Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
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/us/cfr/t26/s§ 28.6694-4·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
(a)In general. For rules relating to the extension of the period of collection when a tax return preparer who prepared a return or claim for refund of the section 2801 tax pays 15 percent of a penalty for understatement of taxpayer's liability, and for procedural matters relating to the investigation, assessment, and collection of the penalties under section 6694(a) and
(b)of the Code, the rules under § 1.6694-4 of this chapter apply.
(b)Applicability date. This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.