31 C.F.R. § 10.78 Decision on appeal.
Title 31 - Money and Finance: Treasury
On appeal from or review of the decision of the Administrative Law Judge, the Secretary of the Treasury, or his or her delegate, will make the agency decision. The Secretary of the Treasury, or his or delegate, will provide a copy of the agency decision to the Director of Practice and the respondent or the respondent's authorized representative. The decision of the Administrative Law Judge will not be reversed unless the appellant establishes that the decision is clearly erroneous in light of the evidence in the record and applicable law. Issues that are exclusively matters of law will be reviewed de novo. In the event that the Secretary of the Treasury, or his or her delegate, determines that there are unresolved issues raised by the record, the case may be remanded to the Administrative Law Judge to elicit additional testimony or evidence. A copy of the agency decision or that of his or her delegate will be provided to the Director of Practice and the respondent contemporaneously.
Title 31: Money and Finance: Treasury
PART 10—PRACTICE BEFORE THE INTERNAL REVENUE SERVICE
Subpart D—Rules Applicable to Disciplinary Proceedings
§ 10.78 Decision on appeal.