26 CFR 31.6694-2 - Penalties for understatement due to an unreasonable position.

§ 31. 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 employment tax under chapters 21 through 25 of subtitle C 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 78454, Dec. 22, 2008]