Joint BoardRegulationsDec 30, 2016related by meaning
(b)(4)(ii) (ii) Advancing frivolous or groundless arguments; or
(b)(4)(iii) (iii) Failing to pursue available administrative remedies.
(b)(5) (5) Has demonstrated a pattern of willful disreputable conduct by—
(b)(5)(i) (i) Failing to make an annual Federal tax return, in violation of the Federal tax laws, during 4 of t…
Joint BoardRegulationsOct 11, 2017related by meaning
(c) (c) Authority to impose monetary penalty
(c)(1) (1) In general.
(c)(1)(i) (i) The Secretary of the Treasury, or delegate, after notice and an opportunity for a proceeding, may impose a monetary penalty on any practitioner who engages in conduct subject to sanction under paragraph (a) of this section.
(c)(1)(ii) (ii…
Joint BoardRegulationsDec 30, 2016related by meaning
(d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved.
(d)(4)(iv) (iv) Public i…
Joint BoardRegulationsDec 30, 2016related by meaning
(f) (f) Other discovery. No discovery other than that specifically provided for in this section is permitted.
Joint BoardRegulationsDec 30, 2016related by meaning
(a)(9) (9) Directly or indirectly attempting to influence, or offering or agreeing to attempt to influence, the official action of any officer or employee of the Internal Revenue Service by the use of threats, false accusations, duress or coercion, by the offer of any special inducement or promise of an advantage, or b…
Joint BoardRegulationsDec 30, 2016related by meaning
(c) (c) Except as provided in § 10.82, a proceeding will not be instituted under this section unless the proposed respondent previously has been advised in writing of the law, facts and conduct warranting such action and has been accorded an opportunity to dispute facts, assert additional facts, and make arguments (inc…
Joint BoardRegulationsNov 15, 2019related by meaning
(a) (a) In general. A practitioner may not charge an unconscionable fee in connection with any matter before the Internal Revenue Service.
Joint BoardRegulationsDec 30, 2016related by meaning
(a) (a) Advertising and solicitation restrictions.
Joint BoardRegulationsDec 30, 2016related by meaning
(a) (a) To the Internal Revenue Service.
(a)(1) (1) A practitioner must, on a proper and lawful request by a duly authorized officer or employee of the Internal Revenue Service, promptly submit records or information in any matter before the Internal Revenue Service unless the practitioner believes in good faith and on…
Circular 230 § 10.24 — Assistance from or to disbarred or suspended persons and former Internal Revenue Service employees. Joint BoardRegulationsDec 30, 2016related by meaning
A practitioner may not, knowingly and directly or indirectly:
Joint BoardRegulationsOct 11, 2017related by meaning
(b) (b) Effective/applicability date. This section is applicable to conduct occurring on or after September 26, 2007.
Joint BoardRegulationsDec 30, 2016related by meaning
(e) (e) Additional time for briefs and responses. Notwithstanding the time for filing briefs and responses provided in paragraphs (b) and (c) of this section, the Secretary of the Treasury, or delegate deciding appeals, may, for good cause, authorize additional time for filing briefs and responses upon a motion of a pa…
Joint BoardRegulationsOct 18, 2016related by meaning
(f)(1)(iii) (iii) Willfully failing to make a Federal tax return in violation of the revenue laws of the United States, or evading, attempting to evade, or participating in any way in evading or attempting to evade any federal tax or payment thereof, knowingly counseling or suggesting to a client or prospective client …
Joint BoardRegulationsDec 30, 2016related by meaning
failure to file annual registration and other notifications by pension plan), 6652(f) (relating to the failure to file information required in connection with certain plans of deferred compensation), 6692 (relating to the failure to file actuarial report), 7805(b) (relating to the extent to which an Internal Revenue Se…
Joint BoardRegulationsDec 30, 2016related by meaning
(c)(1)(vi) (vi) An officer or a regular employee of a governmental unit, agency, or authority may represent the governmental unit, agency, or authority in the course of his or her official duties.
(c)(1)(vii) (vii) An individual may represent any individual or entity, who is outside the United States, before personnel …
Joint BoardRegulationsDec 30, 2016related by meaning
(d) (d) Federal tax matter. A Federal tax matter, as used in this section, is any matter concerning the application or interpretation of—
(d)(1) (1) A revenue provision as defined in section 6110(i)(1)(B) of the Internal Revenue Code;
(d)(2) (2) Any provision of law impacting a person's obligations under the internal r…
Joint BoardRegulationsOct 18, 2016related by meaning
(c)(4) (4) The use of false or misleading representations with intent to deceive a client or prospective client, or of intimations that the actuary is able to obtain special consideration or action from an officer or employee of any agency or court authorized to determine the validity of pension plans under ERISA.
(c)(…
Joint BoardRegulationsDec 30, 2016related by meaning
A practitioner may not unreasonably delay the prompt disposition of any matter before the Internal Revenue Service.
Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) Ex parte communication. The Internal Revenue Service, the respondent, and any representatives of either party, may not attempt to initiate or participate in ex parte discussions concerning a proceeding or potential proceeding with the Administrative Law Judge (or any person who is likely to advise the Administr…
Joint BoardRegulationsDec 30, 2016related by meaning
(a) (a) Any individual subject to the provisions of this part who has (or individuals who have or share) principal authority and responsibility for overseeing a firm's practice governed by this part, including the provision of advice concerning Federal tax matters and preparation of tax returns, claims for refund, or o…