§ 10.67 Proof; variance; amendment of pleadings.

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Title 31 CFR: Money and Finance: Treasury › Part 10: PRACTICE BEFORE THE INTERNAL REVENUE SERVICE › Subpart D: Rules Applicable to Disciplinary Proceedings › § 10.67: § 10.67 Proof; variance; amendment of pleadings.

This text was captured on Aug 14, 2026. It is a snapshot, not a live feed, so check the official code before relying on it.

Text

In the case of a variance between the allegations in pleadings and the evidence adduced in support of the pleadings, the Administrative Law Judge, at any time before decision, may order or authorize amendment of the pleadings to conform to the evidence. The party who would otherwise be prejudiced by the amendment must be given a reasonable opportunity to address the allegations of the pleadings as amended and the Administrative Law Judge must make findings on any issue presented by the pleadings as amended.

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