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 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 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 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 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
(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 BoardRegulationsDec 30, 2016related by meaning
(c) (c) Effective/applicability date. This section is applicable beginning June 12, 2014.
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
(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 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 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
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
(a) (a) A practitioner may not endorse or otherwise negotiate any check (including directing or accepting payment by any means, electronic or otherwise, into an account owned or controlled by the practitioner or any firm or other entity with whom the practitioner is associated) issued to a client by the government in r…
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
(c) (c) Effective/applicability date. Paragraph (a) of this section is applicable on September 26, 2007. Paragraph (b) of this section is applicable beginning June 12, 2014.
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
(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)(4) (4) Practice before the Internal Revenue Service comprehends all matters connected with a presentation to the Internal Revenue Service or any of its officers or employees relating to a taxpayer's rights, privileges, or liabilities under laws or regulations administered by the Internal Revenue Service. Such prese…
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…