( 1) lf any part of an understatement of liability relating to a return of tax under subtitle A of the lnternal Revenue Code of 1954 or claim for ... of proof that he did not negligently disregard a rule or regulation, unless the lnternal Revenue Service presents contrary evidence. ... to the person or persons who so paid, as if the payment were an overpayment of tax, without consideration of any period of limitations.
|Title||:||Rules for tax return preparers|
|Author||:||United States. Internal Revenue Service|