Curious still after re-reading Cir. 230 10.27 Fees. It reads, in part, that except for as provided in paragraph (b)(3) the following. Would charging a contingent fee for penalty abatement/contesting CSED meet the definition below and thus allow for remuneration on a contingency basis? Just need more clarification.
(3) A practitioner may charge a contingent fee
for services rendered in connection with a claim
for credit or refund filed solely in connection with
the determination of statutory interest or penalties
assessed by the Internal Revenue Service.