(a) In general. A person who is a tax return preparer of any return or claim for refund of estate
tax under chapter 11 of subtitle B of the Internal Revenue Code (Code) shall be subject
to penalties under section 6694(b) of the Code 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.
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