Title 26, Internal Revenue CodeRelease 119-102
§7427 Tax Return Preparers
Title 26 › Subtitle F — Procedure and Administration › CHAPTER 76 — JUDICIAL PROCEEDINGS › Subchapter B — Proceedings by Taxpayers and Third Parties › § 7427
Summary
If a preparer is accused of willfully understating tax under section 6694(b), the Secretary must prove it.
Full Legal Text
Title 26, §7427
Internal Revenue Code, Source: USLM XML via OLRC
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.
Legislative History
Notes & Related Subsidiaries
Editorial Notes
Prior Provisions
A prior section 7427 was renumbered 7437 of this title.
Amendments
2007—Pub. L. 110–28 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 AmendmentAmendment by Pub. L. 110–28 applicable to returns prepared after May 25, 2007, see section 8246(c) of Pub. L. 110–28, set out as a note under section 6060 of this title.
Reference
Citations & Metadata
Citation
26 U.S.C. § 7427
Title 26, Internal Revenue Code
Last Updated
Aug 21, 2026
Release point: 119-102