Question: A practitioner may advise a client to submit a document, affidavit, or other paper to the IRS that is overdue that is frivolous that contains

A practitioner may advise a client to submit a document, affidavit, or other paper to the IRS
that is overdue
that is frivolous
that contains or omits information in a manner that demonstrates an intentional disregard of a rule or regulation with no reasonable basis to do so.
the purpose of which is to delay or impede the administration of federal tax laws

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