§ 40.6694-2. Penalties for understatement due to an unreasonable position.
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/us/cfr/t26/s§ 40.6694-2·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 any tax to which this part 40 applies shall be subject to penalties under section 6694(a) 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 78455, Dec. 22, 2008; 74 FR 5106, Jan. 29, 2009]
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§ 40.6694-2
Penalties for understatement due to an unreasonable position.
Treas. Dec.T.D. 9436
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