26 CFR § 31.6694-2 - Penalties for understatement due to an unreasonable position.

---
identifier: "/us/cfr/t26/s31.6694-2"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 31.6694-2 - Penalties for understatement due to an unreasonable position."
title_number: 26
title_name: "Internal Revenue"
section_number: "31.6694-2"
section_name: "Penalties for understatement due to an unreasonable position."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "C"
subchapter_name: "EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE"
part_number: "31"
part_name: "EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE"
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: "T.D. 6516, 25 FR 13032, Dec. 20, 1960; 25 FR 14021, Dec. 31, 1960, unless otherwise noted."
cfr_part: "31"
---


# 31.6694-2 Penalties for understatement due to an unreasonable position.

(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(a) of the Code in the manner stated in § 1.6694-2 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]