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Electronic Code of Federal Regulations

e-CFR data is current as of February 25, 2020

Title 26Chapter ISubchapter DPart 54 → §54.6694-2


Title 26: Internal Revenue
PART 54—PENSION EXCISE TAXES


§54.6694-2   Penalties for understatement due to an unreasonable position.

(a) In general. A person who is a tax return preparer of any return or claim for refund of tax under Chapter 43 of subtitle D 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 78458, Dec. 22, 2008]

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