# Treas. Reg. § 31.6694-3: Penalty for understatement due to willful, reckless, or intentional conduct.

Source: eCFR as of 2026-10-19 <https://www.ecfr.gov/current/title-26/section-31.6694-3>. 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 employment tax under chapters 21 through 25 of subtitle C of the Internal Revenue Code (Code) shall be subject to penalties under section 6694(b) of the Code in the manner stated in § 1.6694-3 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. 

[T.D. 9436, 73 FR 78454, Dec. 22, 2008, as amended by T.D. 9436, 74 FR 5105, Jan. 29, 2009]