Treasury Regulations · 26 CFR
§ 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.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 6694
Cite as 26 CFR § 28.6694-4
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Source
- 90 FR 3395, Jan. 14, 2025, unless otherwise noted.
- Issued under
- 26 U.S.C. § 6694
- Length
- 100 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 1 regulation; cited by 0
¶(a) In general. For rules relating to the extension of the period of collection when a tax return preparer who prepared a return or claim for refund of the section 2801 tax pays 15 percent of a penalty for understatement of taxpayer's liability, and for procedural matters relating to the investigation, assessment, and collection of the penalties under section 6694(a) and (b) of the Code, the rules under § 1.6694-4 of this chapter apply.
¶(b) Applicability date. This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
Where it sits in 26 CFR
- Subchapter B Estate and gift taxes
- Part 28 Imposition of tax on gifts and bequests from covered expatriates
Nearby sections
- § 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.