§ 28.6694-3. 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.
• § 25.6694-3 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.
• § 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.
• § 28.6694-4 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

• § 2801 Imposition of tax
• § 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.

Where it sits in 26 CFR

1. Subchapter B Estate and gift taxes
2. Part 28 Imposition of tax on gifts and bequests from covered expatriates

Nearby sections

• § 28.6109-1 Tax return preparers furnishing identifying numbers for returns or claims for refund.
• § 28.6151-1 Time and place for paying tax shown on returns.
• § 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.
• § 28.6695-1 Other assessable penalties with respect to the preparation of tax returns for other persons.
• § 28.6696-1 Claims for credit or refund by tax return preparers and appraisers.
• § 28.7701-1 Tax return preparer.