Treasury Regulations · 26 CFR
§ 58.6694-1. Section 6694 penalties.
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 § 58.6694-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Source
- T.D. 10002, 89 FR 55049, July 3, 2024, unless otherwise noted.
- Issued under
- 26 U.S.C. § 6694
- Length
- 284 words · about 1 min to read
- Cross-references
- cites 1 Code section and 4 regulations; cited by 0
¶(a) Penalties applicable to tax return preparer. For general definitions regarding penalties under section 6694 of the Internal Revenue Code (Code) applicable to preparers of tax returns or claims for refund of tax under chapter 37 of the Code, see § 1.6694-1 of this chapter.
¶(b) Penalties for understatement due to an unreasonable position. A person who is a tax return preparer of any return or claim for refund of tax under chapter 37 may be subject to penalties under section 6694(a) in the manner stated in § 1.6694-2 of this chapter.
¶(c) Penalties for understatement due to willful, reckless, or intentional conduct. A person who is a tax return preparer of any return or claim for refund of tax under chapter 37 may be subject to penalties under section 6694(b) in the manner stated in § 1.6694-3 of this chapter.
¶(d) 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. The rules under § 1.6694-4 of this chapter, relating to the extension of period of collection when a tax return preparer who prepared a return or claim for refund of tax pays 15 percent of a penalty for understatement of taxpayer's liability and to procedural matters regarding the investigation, assessment, and collection of the penalties under sections 6694(a) and (b), apply to a tax return preparer who prepared a return or claim for refund for tax under chapter 37.
¶(e) Applicability date. This section applies to returns and claims for refund filed, and advice provided, after June 28, 2024, and during taxable years ending after June 28, 2024.
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
- § 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.
Where it sits in 26 CFR
- Subchapter D Miscellaneous excise taxes
- Part 58 Stock repurchase excise tax
- Subpart B Procedure and Administration
Nearby sections
- § 58.6091-1 Place for filing tax returns under chapter 37 of the Internal Revenue Code.
- § 58.6107-1 Tax return preparer must furnish copy of return or claim for refund to taxpayer and must retain a copy or record.
- § 58.6109-1 Tax return preparers furnishing identifying numbers for returns or claims for refund.
- § 58.6151-1 Time and place for paying of tax shown on returns.
- § 58.6694-1 Section 6694 penalties.
- § 58.6695-1 Other assessable penalties with respect to the preparation of tax returns or claims for refund for other persons.
- § 58.6696-1 Claims for credit or refund by tax return preparers.