found, in a final administrative or judicial proceeding, to have engaged in any of the following kinds of conduct: (1) willful failure to obtain the required approval signatures on documents authorizing the seizure of a taxpayer’s home, personal belongings, or business assets; (2) providing a false statement under oath about a material matter involving a taxpayer or a taxpayer representative; (3) with respect to a taxpayer, or a taxpayer representative, or a fellow employee of the Internal Revenue Service, the violation of any right under the U.S. Constitution or any civil right under various specific federal statutes; (4) falsifying or destroying documents to conceal mistakes made by any employee with respect to a matter involving a taxpayer or a taxpayer representative; (5) assault or battery on a taxpayer, a taxpayer representative, or other employee of the Internal Revenue Service, but only if there is a criminal conviction, or a final judgment by a court in a civil case, with respect to the assault or battery; (6) violations of the Internal Revenue Code of 1986, or of Department of Treasury regulations, or of policies of the Internal Revenue Service, to retaliate against or harass a taxpayer, or a taxpayer representative, or a fellow employee of the Internal Revenue Service; (7) willful misuse the provisions of section 6103 of the Internal Revenue Code (relating to confidentiality of tax returns and tax return information) to conceal information from a congressional inquiry; (8) willful failure to timely file any tax return required under the Internal Revenue Code, unless the failure is due to reasonable cause and is not due to willful neglect; (9) willful understatement of a Federal tax liability, unless the understatement is due to reasonable cause and is not due to willful neglect; (10) threatening to audit a taxpayer to extract personal gain or benefit. In fiscal year 2008, the IRS substantiated 320 Section 1203 allegations. Of these, 311 were due to employees’ failure to file a federal tax return or understatement of their tax liability, and would not have affected taxpayers. Stephen A. Whitlock implemented the Service’s plan for mitigation of penalty under Section 1203 of the Restructuring and Reform Act of 1998 and set up the processes and procedures for the Commissioner’s Review Board. Tax collection activities The Act also provided that certain assessments and levies must have the approval of IRS legal counsel. The Act also provided that the