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
(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 BoardRegulationsNov 15, 2019related by meaning
(a) (a) Tax returns.
(a)(1) (1) A practitioner may not willfully, recklessly, or through gross incompetence—
(a)(1)(i) (i) Sign a tax return or claim for refund that the practitioner knows or reasonably should know contains a position that—
(a)(1)(i)(A) (A) Lacks a reasonable basis;
(a)(1)(i)(B) (B) Is an unreasonable …
Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) Any such individual who has (or such individuals who have or share) principal authority as described in paragraph (a) of this section will be subject to discipline for failing to comply with the requirements of this section if—
(b)(1) (1) The individual through willfulness, recklessness, or gross incompetence d…
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 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 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 BoardRegulationsOct 11, 2017related by meaning
(a) (a) A practitioner may be sanctioned under § 10.50 if the practitioner—
(a)(1) (1) Willfully violates any of the regulations (other than § 10.33) contained in this part; or
(a)(2) (2) Recklessly or through gross incompetence (within the meaning of § 10.51(a)(13)) violates § 10.34, § 10.35, § 10.36 or § 10.37.
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 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) 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 BoardRegulationsDec 30, 2016related by meaning
(a)(3) (3) When a proper and lawful request is made by a duly authorized officer or employee of the Internal Revenue Service, concerning an inquiry into an alleged violation of the regulations in this part, a practitioner must provide any information the practitioner has concerning the alleged violation and testify reg…
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…
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 may not unreasonably delay the prompt disposition of any matter before the Internal Revenue Service.
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…
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
(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…