31 C.F.R. § 10.52
Violations subject to sanction
(a) A practitioner may be sanctioned under § 10.50 if the practitioner—
(1) Willfully violates any of the regulations (other than § 10.33) contained in this part; or
(2) Recklessly or through gross incompetence (within the meaning of § 10.51(a)(13)) violates § 10.34, § 10.35, § 10.36 or § 10.37.
(b) Effective/applicability date. This section is applicable to conduct occurring on or after September 26, 2007.
Notes of Decisions
Cited in 2
cases, 1974–1985 · leading case: Joslin v. Sec'y of Dep't of Treasury, 616 F. Supp. 1023 (D. Utah 1985).
Joslin v. Sec'y of Dep't of Treasury, 616 F. Supp. 1023 (D. Utah 1985). “33 (1984) and 31 C.F.R. § 10.52 (1984). Those regulations became effective in May, 1984, and are apparently the first to provide guidelines directed at practitioners who render tax shelter opinions.”
United States v. Houston H. Feaster, 494 F.2d 871 (5th Cir. 1974). “This regulation is found under the general heading “Duties and Restrictions Relating to Practice Before the Internal Revenue Service” and the sanction for its violation is the possibility of being disbarred or suspended from practicing before the Internal Revenue Service, 31…”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.