26 CFR § 157.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct.

---
identifier: "/us/cfr/t26/s157.6694-3"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 157.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct."
title_number: 26
title_name: "Internal Revenue"
section_number: "157.6694-3"
section_name: "Penalty for understatement due to willful, reckless, or intentional conduct."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "D"
subchapter_name: "MISCELLANEOUS EXCISE TAXES"
part_number: "157"
part_name: "EXCISE TAX ON STRUCTURED SETTLEMENT FACTORING TRANSACTIONS"
positive_law: false
currency: "2026-03-24"
last_updated: "2026-03-24"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 7805."
regulatory_source: "T.D. 9134, 69 FR 41193, July 8, 2004, unless otherwise noted."
cfr_part: "157"
---


# 157.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.

(a) *In general.* A person who is a tax return preparer of any return or claim for refund of tax under section 5891 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 78462, Dec. 22, 2008]