In any proceeding involving the issue of whether or not a tax return preparer has willfully attempted in any manner to understate the liability for tax (within the meaning of section 6694(b)), the burden of proof in respect to such issue shall be upon the Secretary.
Pub. L. 94–455, title XII, § 1203(b)(2)(A)90 Stat. 1690Pub. L. 110–28, title VIII, § 8246(a)(2)(J)(i)121 Stat. 202(Added , , ; amended , , .)
Editorial Notes
Prior Provisions
A prior section 7427 was renumbered 7437 of this title.
Amendments
Pub. L. 110–282007— substituted “Tax return preparers” for “Income tax return preparers” in section catchline and “a tax return preparer” for “an income tax return preparer” in text.
Statutory Notes and Related Subsidiaries
Effective Date of 2007 Amendment
Pub. L. 110–28section 8246(c) of Pub. L. 110–28section 6060 of this titleAmendment by applicable to returns prepared after , see , set out as a note under .