 The return of client records. In general, a practitioner must, at the request of a client, properly return any and all records that the client, that are necessary for the client to comply with his or her federal tax obligations. So it's kind of, you would think this is obvious, but you get in these situations, especially when there's fees that aren't paid or something like that, where the tax preparer doesn't give back and actually refuses to give back the documents and whatnot. And obviously they're not the tax preparer's documents, they're only there so that you can prepare the tax returns. And so you got to give them back to the client and it seems pretty clear. So the practitioner may retain copies of the records returned to a client. So you might make copies in the event that you have to justify positions and whatnot, but you would give the originals back, you would think that's the general process. The existence of a dispute over fees generally does not relieve the practitioner of his or her responsibility under this section. So if you're gonna say, well, if you don't pay my fee, I'm not gonna give you your documents back. That's just seems childish, but you know, that happens. Nonetheless, if applicable state law allows or permits the retention of a client's records by a practitioner in the case of a dispute over fees for service rendered, the practitioner need only return those records that must be attached to the taxpayer's return. So the practitioner, however, must provide the client with reasonable access to review and copy any additional records of the client retained by the practitioner under state law that are necessary for the client to comply with his or her federal tax obligations. So then we have conflicting interests. Except as provided by paragraph B of this section, a practitioner shall not represent a client before the internal revenue service if the representation involves a conflict of interest, a conflict of interest exists if. Now note, clearly this should be intuitively kind of makes sense if you're gonna represent someone saying you are my agent, you're acting on my behalf, I'm paying you to make decisions for me, your job is to make decisions that are best for me in my interest. Now you already have an agency issue no matter what because even though you're kind of on the same side, there's always gonna be this kind of agency problem where certain decisions are gonna benefit the agent differently than the tax preparer. We don't wanna complicate the situation by having a complete conflict of interest between someone who's supposed to be acting as an agent but has interest that might be counter to that action. So the representation of one client will be directly adverse to another client. So if you've got two clients, obviously it'd be like you're trying to represent both sides of like a divorce case. That doesn't make any sense, right? You can't really, I mean, if they're at odds, you know, then you have to represent one or the other if it's a mutually exclusive kind of thing you would think. So, and even if you're saying, well, that's not true, like I have had a lot of people argue, they say, well, that's not true because I can be fair, I can be just even though there's two people that have these different interests, that may well be, but even still, you can see why they wouldn't wanna do it because you don't look to be fair, it doesn't look to be just, right? No matter what you say, someone's gonna argue that you're not being fair, even if you totally are being fair, and so the fact that that appearance is wrong would mean that someone else would be better suited for that position just due to appearance alone, you would think. So there is a significant risk that the representation of one or more clients will be materially limited by the practitioner's responsibility to another client, a former client or third person or by a personal interest of the practitioner.