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
(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 BoardRegulationsOct 18, 2016related by meaning
(f)(3)(i) (i) When it is determined that the request for access to records will be denied (whether in whole or in part or subject to conditions or exceptions), the person making the request shall be so notified by mail in accordance with paragraph (f)(1) of this section. The letter of notification shall contain a state…
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…
Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) Whenever a penalty has been assessed against an appraiser under the Internal Revenue Code and an appropriate officer or employee in an office established to enforce this part determines that the appraiser acted willfully, recklessly, or through gross incompetence with respect to the proscribed conduct, the appr…
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
In cases where the hearing is stenographically reported by a Government contract reporter, copies of the transcript may be obtained from the reporter at rates not to exceed the maximum rates fixed by contract between the Government and the reporter. Where the hearing is stenographically reported by a regular employee o…
Joint BoardRegulationsDec 30, 2016related by meaning
(c) (c) Effective/applicability date. This section is applicable beginning June 12, 2014.
Circular 230 § 10.63(b) — Service of complaint; service of other papers; service of evidence in support of complaint; filing of papers. Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) Service of papers other than complaint. Any paper other than the complaint may be served on the respondent, or his or her authorized representative under § 10.69(a)(2) by:
(b)(1) (1) Mailing the paper by first class mail to the last known address (as determined under section 6212 of the Internal Revenue Code an…
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 18, 2016related by meaning
(f) (f) Records not subject to correction. The following records are not subject to correction or amendment by individuals:
(f)(1) (1) Transcripts or written statements made under oath;
(f)(2) (2) Transcripts of Grand Jury proceedings, judicial or quasi-judicial proceedings which form the official record of those proce…
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
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 BoardRegulationsOct 11, 2017related by meaning
(b) (b) Effective/applicability date. This section is applicable to conduct occurring on or after September 26, 2007.
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
(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 BoardRegulationsOct 18, 2016related by meaning
The guardian of a person judicially determined to be incompetent shall, in addition to establishing the identity of the person he represents, establish his own guardianship by furnishing a copy of a court order establishing the guardianship and may thereafter act on behalf of such individual. (See 5 U.S.C. 552a(h)).