Section 41.6694-3 - 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 excise tax under section 4481 shall be subject to penalties under section 6694(b) 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 78456 , Dec. 22, 2008