§ 20.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
26 C.F.R. Part 20 — Estate Tax; Estates Of Decedents Dying After August 16, 1954 · 2026 edition · updated 2026-10-04 · United States
(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(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.
[T.D. 9436, 73 FR 78451, Dec. 22, 2008]
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