A CTRS practitioner charges a contingency fee based on the amount of tax saved for a client whose case is before the IRS Appeals Office. Under Circular 230, this fee arrangement is:
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A
Permitted because Appeals is an administrative proceeding
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B
Permitted only if the client consents in writing
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C
Generally prohibited for matters before the IRS
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D
Permitted for tax resolution matters involving balances over $50,000