Joint BoardRegulationsNov 15, 2019related by meaning
(b) (b) Documents, affidavits and other papers.
(b)(1) (1) A practitioner may not advise a client to take a position on a document, affidavit or other paper submitted to the Internal Revenue Service unless the position is not frivolous.
(b)(2) (2) A practitioner may not advise a client to submit a document, affidavit o…
Joint BoardRegulationsNov 6, 2020related by meaning
(b)(4) (4) No former Government employee may, within one year after Government employment is ended, communicate with or appear before, with the intent to influence, any employee of the Treasury Department in connection with the publication, withdrawal, amendment, modification, or interpretation of a rule the developmen…
Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) To whom applicable. This section applies to any practitioner who, within 5 years prior to the date that a show cause order under this section's expedited suspension procedures is served:
(b)(1) (1) Has had a license to practice as an attorney, certified public accountant, or actuary suspended or revoked for cau…
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
(a)(2) (2) Where the requested records or information are not in the possession of, or subject to the control of, the practitioner or the practitioner's client, the practitioner must promptly notify the requesting Internal Revenue Service officer or employee and the practitioner must provide any information that the pr…
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 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
(c) (c) Destruction of report. No report made under paragraph (a) or (b) of this section shall be maintained unless retention of the report is permissible under the applicable records control schedule as approved by the National Archives and Records Administration and designated in the Internal Revenue Manual. Reports …
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 BoardRegulationsDec 30, 2016related by meaning
(c) (c) Applicability date. This section is effective after June 20, 2005.
Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) Depositions upon oral examination
(b)(1) (1) A deposition must be taken before an officer duly authorized to administer an oath for general purposes or before an officer or employee of the Internal Revenue Service who is authorized to administer an oath in Federal tax law matters.
(b)(2) (2) In ordering a depos…
Joint BoardRegulationsDec 30, 2016related by meaning
Any proceeding instituted under this part prior to June 12, 2014, for which a final decision has not been reached or for which judicial review is still available is not affected by these revisions. Any proceeding under this part based on conduct engaged in prior to June 12, 2014, which is instituted after that date, wi…
Joint BoardRegulationsDec 30, 2016related by meaning
(a) (a) Whenever it is determined that a practitioner (or employer, firm or other entity, if applicable) violated any provision of the laws governing practice before the Internal Revenue Service or the regulations in this part, the practitioner may be reprimanded or, in accordance with § 10.62, subject to a proceeding …
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…
Joint BoardRegulationsDec 30, 2016related by meaning
(a) (a) This part contains rules governing the recognition of attorneys, certified public accountants, enrolled agents, enrolled retirement plan agents, registered tax return preparers, and other persons representing taxpayers before the Internal Revenue Service. Subpart A of this part sets forth rules relating to the …
Joint BoardRegulationsDec 30, 2016related by meaning
A practitioner who, having been retained by a client with respect to a matter administered by the Internal Revenue Service, knows that the client has not complied with the revenue laws of the United States or has made an error in or omission from any return, document, affidavit, or other paper which the client submitte…
Joint BoardRegulationsNov 15, 2019related by meaning
(b) (b) Contingent fees.
(b)(1) (1) Except as provided in paragraphs (b)(2), (3), and (4) of this section, a practitioner may not charge a contingent fee for services rendered in connection with any matter before the Internal Revenue Service.
(b)(2) (2) A practitioner may charge a contingent fee for services rendered i…
Joint BoardRegulationsDec 30, 2016related by meaning
(d) (d) Effective/applicability date. This section is applicable on September 26, 2007.
Joint BoardRegulationsDec 30, 2016related by meaning
(c) (c) Application of rules to other individuals. Any individual who for compensation prepares, or assists in the preparation of, all or a substantial portion of a document pertaining to any taxpayer's tax liability for submission to the Internal Revenue Service is subject to the duties and restrictions relating to pr…
Joint BoardFinal Rules (FR)Dec 28, 2010related by meaning
h respect to this rule are unnecessary, and good cause for making this direct final rule effective 90 days after publication in the
Federal Register
. Pursuant to Executive Order 12866, it has been determined that this direct final rule is not a significant regulatory action, and therefore, does not require a regulator…