Sec. 54.6694-2 Penalties for understatement due to an unreasonable position.

(a) In general.

A person who is a tax return preparer of any return or claim for refund of tax under chapter 43 of subtitle D of the Internal Revenue Code (Code) shall be subject to penalties under section 6694(a) of the Code in the manner stated in § 1.6694-2 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.