SECTION 3. DRAFTING

INFORMATION

The principal author of this announcement is Jean Elting Rowe of the Large

Business and International Division. However, other personnel from the Treasury Department and the Office of Associate Chief Counsel (Energy, Credits, and Excise Tax) participated in its develop

ment. For further information regarding this announcement, call (202) 317-5254 (not a toll-free number).

1 The IRS allocated approximately $4 billion of the § 48C credits in the first allocation round (Round 1) of the § 48C(e) program. See Announcement 2025-22 in I.R.B. 2025-50.

December 8, 2025 784 Bulletin No. 2025–50

hearing. After 30 days from the issuance of the decision, in the absence of an appeal, the ALJ’s decision becomes the final agency decision.

Disbarred by default decision, Sus- pended by default decision, Censured by default decision, Monetary pen- alty imposed by default decision, and Disqualified by default decision —An ALJ, after finding that no answer to the OPR’s complaint was filed or timely filed, granted the OPR’s motion for a default judgment and issued a decision imposing one of these sanctions.

Disbarred by decision on appeal, Suspended by decision on appeal, Cen- sured by decision on appeal, Mone- tary penalty imposed by decision on appeal, and Disqualified by decision on appeal —The decision of the ALJ was appealed to the agency’s appellate authority, acting as the delegate of the Secretary of the Treasury, and the appellate authority issued a decision imposing one of these sanctions.

Disbarred by consent, Suspended by consent, Censured by consent, Mone- tary penalty imposed by consent, and Disqualified by consent —In lieu of a disciplinary proceeding being instituted or continued, an individual offered their consent to one of these sanctions (or a firm or other entity offered to consent to a monetary penalty) and the OPR accepted the offer and the parties entered into a consent agreement. Typically, an offer of consent will provide for: suspension for an indefinite term; conditions that the individual must observe during the suspension; and the individual’s opportunity, after a stated number of months, to file with the OPR a petition for reinstatement affirming compliance with the terms of the consent agreement and affirming current fitness and eligibility to practice ( i.e ., an active professional license or active enrollment status, with no intervening violations of the regulations).

Suspended indefinitely by decision in expedited proceeding, Suspended indefinitely by default decision in expe- dited proceeding —The OPR instituted an expedited proceeding for suspension (based on certain limited grounds, including loss of a professional license for cause, and criminal convictions) that resulted in suspension.

Announcement of Disciplinary Sanctions From the Office of Professional Responsibility