Daily eCFR

§ 157.6694-2 Penalties for understatement due to an unreasonable position.

26 CFR 157.6694-2

Citation26 CFR 157.6694-2

CorpusDaily eCFR

Displayed edition2026-10-01

Last updated2026-10-01

§ 157.6694-2 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 section 5891 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 78462, Dec. 22, 2008]

Authority26 U.S.C. 7805. Section 157.6001-1 also issued under 26 U.S.C. 6001; Section 157.6011-1 also issued under 26 U.S.C. 6011; Section 157.6061-1 also issued under 26 U.S.C. 6061; Section 157.6071-1 also issued under 26 U.S.C. 6071; Section 157.6081-1 also issued under 26 U.S.C. 6081(a); Section 157.6091-1 also issued under 26 U.S.C. 6091; Section 157.6060-1 also issued under 26 U.S.C. 6060(a); Section 157.6109-1 also issued under 26 U.S.C. 6109(a); Section 157.6109-2 also issued under 26 U.S.C. 6109(a); Section 157.6161-1 also issued under 26 U.S.C. 6161; Section 157.6695-1 also issued under 26 U.S.C. 6695(b).

SourceT.D. 9134, 69 FR 41193, July 8, 2004, unless otherwise noted.