Implements § 6694Open in workspace
Reg. § 20.6694-4 Extension of period of collection when preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
26 CFR § 20.6694-4eCFR, current through 2026-07-14
(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 for estate tax under chapter 11 of subtitle B of the Internal Revenue Code pays 15 percent of a penalty for understatement of the taxpayer's liability, and procedural matters relating to the investigation, assessment and collection of the penalties under sections and (b), the rules under will apply.
(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 78451, Dec. 22, 2008]
Source: decipher.legal/cfr/26/20.6694-4 · Treasury Regulations (26 CFR), eCFR data as of 2026-07-14