Preparer Penalty for Understatement Due To Unrealistic Position

Preparer Penalty for Understatement Due To Unrealistic Position means:
a $250 penalty on a preparer who files a return knowing that a position he or she has taken does not have a realistic possibility of success if challenged administratively or litigated, and the position is not disclosed. Former IRC (check if this IRC provision is current here) §6694(a).