Code of Federal Regulations (alpha)

CFR /  Title 26  /  Part 25  /  Sec. 25.6694-3 Penalty for understatement due to willful, reckless,

(a) In general. A person who is a tax return preparer of any return or claim for refund of gift tax under chapter 12 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 Sec. 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 78452, Dec. 22, 2008]