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
(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
(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
(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
(a)(2) (2) A practitioner may not make, directly or indirectly, an uninvited written or oral solicitation of employment in matters related to the Internal Revenue Service if the solicitation violates Federal or State law or other applicable rule, e.g., attorneys are precluded from making a solicitation that is prohibit…
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 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
(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 …
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
(d) (d) Exemptions. The procedures specified in paragraphs (a), (b) and (c) of this section shall not apply to: (1) Systems of records exempted pursuant to 5 U.S.C. 552a(k); (2) information compiled in reasonable anticipation of a civil action or proceeding (see 5 U.S.C. 552a(d)(5)); or (3) information regarding an ind…
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 BoardRegulationsNov 6, 2020related by meaning
(a)(5) (5) Rule includes Treasury regulations, whether issued or under preparation for issuance as notices of proposed rulemaking or as Treasury decisions, revenue rulings, and revenue procedures published in the Internal Revenue Bulletin (see 26 CFR 601.601(d)(2)(ii)(b)).
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
(c)(2)(iii) (iii) With respect to subsections (d) (2), (3) and (4), (e)(4)(H), and (f)(4), the Joint Board believes that the imposition of these requirements, which presuppose access and provide for amending records, would impair the ability to conduct investigations and would be unnecessary for the same reasons stated…
Joint BoardRegulationsDec 30, 2016related by meaning
(c) (c) Effective/applicability date. This section is applicable beginning June 12, 2014.
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 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
(a) (a) Roster. The Internal Revenue Service will maintain and make available for public inspection in the time and manner prescribed by the Secretary, or delegate, the following rosters—
(a)(1) (1) Individuals (and employers, firms, or other entities, if applicable) censured, suspended, or disbarred from practice befo…