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26 U.S.C. § 7525 — Confidentiality privileges relating to taxpayer communications
Federal law — U.S. Code and appendices · legal_authorities
**(a) Uniform application to taxpayer communications with federally authorized practitioners**
(1) **General rule** — With respect to tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall also apply to a communication between a taxpayer and any federally authorized tax practitioner to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney.
(2) **Limitations** — Paragraph (1) may only be asserted in—
(A) any noncriminal tax matter before the Internal Revenue Service; and
(B) any noncriminal tax proceeding in Federal court brought by or against the United States.
(3) **Definitions** — For purposes of this subsection—
(A) *Federally authorized tax practitioner* — The term “federally authorized tax practitioner” means any individual who is authorized under Federal law to practice before the Internal Revenue Service if such practice is subject to Federal regulation under [section 330 of title 31](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title31-section330&num=0&edition=prelim), United States Code.
(B) *Tax advice* — The term “tax advice” means advice given by an individual with respect to a matter which is within the scope of the individual’s authority to practice described in subparagraph (A).
**(b) Section not to apply to communications regarding tax shelters** The privilege under subsection (a) shall not apply to any written communication which is—
(1) between a federally authorized tax practitioner and—
(A) any person,
(B) any director, officer, employee, agent, or representative of the person, or
(C) any other person holding a capital or profits interest in the person, and
(2) i
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Source file: Laws/federal/codes/united-states-code/title-26/section-7525-confidentiality-privileges-relating-to-taxpayer-communications--f44a819fa9.md
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Source location: Title 26, Chapter 77, § 7525; chapter-077-miscellaneous-provisions.md
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**(a) Uniform application to taxpayer communications with federally authorized practitioners**
(1) **General rule** — With respect to tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall also apply to a communication between a taxpayer and any federally authorized tax practitioner to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney.
(2) **Limitations** — Paragraph (1) may only be asserted in—
(A) any noncriminal tax matter before the Internal Revenue Service; and
(B) any noncriminal tax proceeding in Federal court brought by or against the United States.
(3) **Definitions** — For purposes of this subsection—
(A) *Federally authorized tax practitioner* — The term “federally authorized tax practitioner” means any individual who is authorized under Federal law to practice before the Internal Revenue Service if such practice is subject to Federal regulation under [section 330 of title 31](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title31-section330&num=0&edition=prelim), United States Code.
(B) *Tax advice* — The term “tax advice” means advice given by an individual with respect to a matter which is within the scope of the individual’s authority to practice described in subparagraph (A).
**(b) Section not to apply to communications regarding tax shelters** The privilege under subsection (a) shall not apply to any written communication which is—
(1) between a federally authorized tax practitioner and—
(A) any person,
(B) any director, officer, employee, agent, or representative of the person, or
(C) any other person holding a capital or profits interest in the person, and
(2) in connection with the promotion of the direct or indirect participation of the person in any tax shelter (as defined in section 6662(d)(2)(C)(ii)).
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Federal law — U.S. Code and appendices · legal_authorities
**(a)** Subject to [section 500 of title 5](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title5-section500&num=0&edition=prelim), the Secretary of the Treasury may—
(1) regulate the practice of representatives of persons before the Department of the Treasury; and
(2) before admitting a representative to practice, require that the representative demonstrate—
(A) good character;
(B) good reputation;
(C) necessary qualifications to enable the representative to provide to persons valuable service; and
(D) competency to advise and assist persons in presenting their cases.
**(b)** Any enrolled agents properly licensed to practice as required under rules promulgated under subsection (a) shall be allowed to use the credentials or designation of “enrolled agent”, “EA”, or “E.A.”.
**(c)** After notice and opportunity for a proceeding, the Secretary may suspend or disbar from practice before the Department, or censure, a representative who—
(1) is incompetent;
(2) is disreputable;
(3) violates regulations prescribed under this section; or
(4) with intent to defraud, willfully and knowingly misleads or threatens the person being represented or a prospective person to be represented.
The Secretary may impose a monetary penalty on any representative described in the preceding sentence. If the representative was acting on behalf of an employer or any firm or other entity in connection with the conduct giving rise to such penalty, the Secretary may impose a monetary penalty on such employer, firm, or entity if it knew, or reasonably should have known, of such conduct. Such penalty shall not exceed the gross income derived (or to be derived) from the conduct giving rise to the penalty and may be in addition to, or in lieu of, any suspension, disbarmen
Source: Supplied U.S. Code snapshot — release unconfirmed · 31 U.S.C. § 330
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Federal law — U.S. Code and appendices · legal_authorities
Page 3963
TITLE 26—INTERNAL REVENUE CODE
§ 7525
1996—Subsec. (b)(3)(C). Pub. L. 104–193, § 110(l)(4), for-
merly § 110(l)(8), as renumbered by Pub. L. 105–33, sub-
stituted ‘‘assistance under a State program funded
under part A of title IV of the Social Security Act’’ for
‘‘aid to families with dependent children’’.
Statutory Notes and Related Subsidiaries
EFFECTIVE DATE OF 2008 AMENDMENT
Amendment of this section and repeal of Pub. L.
110–234 by Pub. L. 110–246 effective May 22, 2008, the
date of enactment of Pub. L. 110–234, except as other-
wise provided, see section 4 of Pub. L. 110–246, set out
as an Effective Date note under section 8701 of Title 7,
Agriculture.
Amendment by section 4002(b)(1)(E), (2)(O) of Pub. L.
110–246 effective Oct. 1, 2008, see section 4407 of Pub. L.
110–246, set out as a note under section 1161 of Title 2,
The Congress.
EFFECTIVE DATE OF 1996 AMENDMENT
Amendment by Pub. L. 104–193 effective July 1, 1997,
with transition rules relating to State options to accel-
erate such date, rules relating to claims, actions, and
proceedings commenced before such date, rules relating
to closing out of accounts for terminated or substan-
tially modified programs and continuance in office of
Assistant Secretary for Family Support, and provisions
relating to termination of entitlement under AFDC
program, see section 116 of Pub. L. 104–193, as amended,
set out as an Effective Date note under section 601 of
Title 42, The Public Health and Welfare.
EFFECTIVE DATE
Pub. L. 101–508, title XI, § 11622(c), Nov. 5, 1990, 104
Stat. 1388–505, provided that: ‘‘The amendments made
by this section [enacting this section] shall apply to in-
structions prepared for taxable years beginning after
1990.’’
§ 7524. Annual notice of tax delinquency
N
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 7525
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