26 CFR § 28.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct.

---
identifier: "/us/cfr/t26/s28.6694-3"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 28.6694-3 - Penalty for understatement due to willful, reckless, or intentional conduct."
title_number: 26
title_name: "Internal Revenue"
section_number: "28.6694-3"
section_name: "Penalty for understatement due to willful, reckless, or intentional conduct."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "B"
subchapter_name: "ESTATE AND GIFT TAXES"
part_number: "28"
part_name: "IMPOSITION OF TAX ON GIFTS AND BEQUESTS FROM COVERED EXPATRIATES"
positive_law: false
currency: "2026-04-05"
last_updated: "2026-04-05"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 7805."
regulatory_source: "90 FR 3395, Jan. 14, 2025, unless otherwise noted."
cfr_part: "28"
---


# 28.6694-3 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 any section 2801 tax is subject to penalties under section 6694(b) of the Code in the manner stated in § 1.6694-3 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.