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10 Probate & ProPerty j November/December 2008Probate & ProPerty j November/December 2008 11 Section 6694 of the Internal Revenue Code was implemennte with the passage of the Tax Reform Act of 1976, Pub. L. No. 94-455, 90 Stat. 1520. It authorized the imposition of penalties on those who prepare income tax returns for compensation regardless of their educational background or profession—lawyers or accountants—under certain circumsttances In the event the amount of income tax on a tax return or...