Circular 230

Circular 230 is the Treasury Department publication that governs the practice of tax professionals before the IRS, establishing standards of conduct, penalties for violations, and rules for written tax advice.

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Exam Tip

Circular 230 is HEAVILY tested on Part 3. Key topics: due diligence, conflicts of interest, return of client records, advertising rules, contingent fees (generally prohibited for original returns).

What is Circular 230?

Circular 230 (31 CFR Part 10) is the Treasury Department's regulations governing who may practice before the IRS and the rules they must follow. It applies to EAs, CPAs, attorneys, and other authorized practitioners.

Key Provisions

TopicRule
Due diligenceMust exercise due diligence in preparing returns and documents
Conflicts of interestMust obtain written informed consent from all parties
Client recordsMust return client records upon request (even if fees unpaid)
AdvertisingCannot make false or misleading claims
Contingent feesGenerally prohibited for original returns
Written tax adviceMust consider all relevant facts and not rely on unreasonable assumptions

Penalties for Violations

  • Censure (public reprimand)
  • Suspension from practice
  • Disbarment from practice before IRS
  • Monetary penalties

Exam Alert

Circular 230 is HEAVILY tested on EA Part 3. Focus on: due diligence requirements, conflicts of interest (written consent), return of client records (must return even if fees are owed), advertising rules, and contingent fees (prohibited for original returns but allowed for amended returns and claims for refund).

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