# Treas. Reg. § 28.6694-2: Penalties for understatement due to an unreasonable position.

Source: eCFR as of 2026-10-19 <https://www.ecfr.gov/current/title-26/section-28.6694-2>. Interprets 26 U.S.C. § 6694.

(a) In general. A person who is a tax return preparer of any return or claim for refund of any section 2801 tax is subject to penalties under section 6694(a) of the Code in the manner stated in § 1.6694-2 of this chapter. 

(b) Applicability date. This section applies to returns and claims for refund filed, and advice provided, on or after January 14, 2025.