Section 25.6694-2 - 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 gift tax under chapter 12 of subtitle B 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 78451 , Dec. 22, 2008