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
(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)(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 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 BoardRegulationsNov 6, 2020related by meaning
(b) (b) General rules.
(b)(1) (1) No former Government employee may, subsequent to Government employment, represent anyone in any matter administered by the Internal Revenue Service if the representation would violate 18 U.S.C. 207 or any other laws of the United States.
(b)(2) (2) No former Government employee who per…
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 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 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
(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
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
(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 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
(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
A practitioner may not unreasonably delay the prompt disposition of any matter before the Internal Revenue Service.
Joint BoardRegulationsOct 18, 2016related by meaning
…y to the Executive Director, Joint Board for the Enrollment of Actuaries, 2401 E Street, NW., suite 1537, Washington, DC. Any request for amendment of records or any appeal from the initial denial of a request which does not fully comply with the requirements of this section will not be deemed subject to the time const…
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 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 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 BoardRegulationsOct 18, 2016related by meaning
(c) (c) Filing of papers. Whenever the filing of a paper is required or permitted in connection with a suspension or termination proceeding, and the place of filing is not specified by this subpart or by rule or order of the Administrative Law Judge, the paper shall be filed with the Executive Director of the Joint Boa…