§ 25.6694-3. Penalty for understatement due to willful, reckless, or intentional conduct.

Other regulations under § 6694

• § 1.6694-0 Table of contents.
• § 1.6694-1 Section 6694 penalties applicable to tax return preparers.
• § 1.6694-2 Penalty for understatement due to an unreasonable position.
• § 1.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
• § 1.6694-4 Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
• § 20.6694-1 Section 6694 penalties applicable to tax return preparer.
• § 20.6694-2 Penalties for understatement due to an unreasonable position.
• § 20.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
• § 20.6694-4 Extension of period of collection when preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
• § 25.6694-1 Section 6694 penalties applicable to tax return preparer.
• § 25.6694-2 Penalties for understatement due to an unreasonable position.
• § 25.6694-4 Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
• § 26.6694-1 Section 6694 penalties applicable to tax return preparer.
• § 26.6694-2 Penalties for understatement due to an unreasonable position.
• § 26.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
• § 26.6694-4 Extension of period of collection when preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
• § 28.6694-1 Section 6694 penalties applicable to return preparer.
• § 28.6694-2 Penalties for understatement due to an unreasonable position.
• § 28.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
• § 28.6694-4 Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
• § 31.6694-1 Section 6694 penalties applicable to tax return preparer.
• § 31.6694-2 Penalties for understatement due to an unreasonable position.
• § 31.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
• § 31.6694-4 Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
• § 40.6694-1 Section 6694 penalties applicable to tax return preparer.
• § 40.6694-2 Penalties for understatement due to an unreasonable position.
• § 40.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
• § 40.6694-4 Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
• § 41.6694-1 Section 6694 penalties applicable to tax return preparer.
• § 41.6694-2 Penalties for understatement due to an unreasonable position.

Cross-references

Computed from the citations in the text of 26 CFR.

Code sections it cites

• § 6694 Understatement of taxpayer’s liability by tax return preparer

Regulations it cites

• § 1.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.

Amendment history

From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.

1. December 22, 2008Issued by T.D. 9436 (73 FR 78452)

Where it sits in 26 CFR

1. Subchapter B Estate and gift taxes
2. Part 25 Gift tax; gifts made after december 31, 1954
3. Procedure and Administration

Nearby sections

• § 25.6324-1 Special lien for gift tax.
• § 25.6601-1 Interest on underpayment, nonpayment, or extensions of time for payment, of tax.
• § 25.6694-1 Section 6694 penalties applicable to tax return preparer.
• § 25.6694-2 Penalties for understatement due to an unreasonable position.
• § 25.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
• § 25.6694-4 Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
• § 25.6695-1 Other assessable penalties with respect to the preparation of tax returns for other persons.
• § 25.6696-1 Claims for credit or refund by tax return preparers.
• § 25.6905-1 Discharge of executor from personal liability for decedent's income and gift taxes.