26 CFR § 26.6694-4 - Extension of period of collection when preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
---
identifier: "/us/cfr/t26/s26.6694-4"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 26.6694-4 - Extension of period of collection when preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters."
title_number: 26
title_name: "Internal Revenue"
section_number: "26.6694-4"
section_name: "Extension of period of collection when preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "B"
subchapter_name: "ESTATE AND GIFT TAXES"
part_number: "26"
part_name: "GENERATION-SKIPPING TRANSFER TAX REGULATIONS UNDER THE TAX REFORM ACT OF 1986"
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 and 26 U.S.C. 2663."
regulatory_source: "T.D. 8644, 60 FR 66903, Dec. 27, 1995, unless otherwise noted."
cfr_part: "26"
---
# 26.6694-4 Extension of period of collection when preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
(a) *In general.* For rules relating to the extension of period of collection when a tax return preparer who prepared a return or claim for refund for generation-skipping transfer tax under chapter 13 of subtitle B of the Internal Revenue Code pays 15 percent of a penalty for understatement of taxpayer's liability, and procedural matters relating to the investigation, assessment and collection of the penalties under section 6694(a) and (b), the rules under § 1.6694-4 of this chapter 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 78453, Dec. 22, 2008]