10.29—Conflicting interests.
        
        (a) 
         Except as provided by paragraph (b) of this
 section, a practitioner shall not represent a
 client before the Internal Revenue Service if the
 representation involves a conflict of interest. A
 conflict of interest exists if—
    
    
    
        
        (2) 
         There is a significant risk that the
 representation of one or more clients will be
 materially limited by the practitioner's
 responsibilities to another client, a former
 client or a third person, or by a personal
 interest of the practitioner.
    
    
        
        (b) 
         Notwithstanding the existence of a conflict
 of interest under paragraph (a) of this section,
 the practitioner may represent a client if—
    
    
        
        (1) 
         The practitioner reasonably believes that
 the practitioner will be able to provide competent
 and diligent representation to each affected
 client;
    
    
    
        
        (3) 
         Each affected client waives the conflict of
 interest and gives informed consent, confirmed in
 writing by each affected client, at the time the
 existence of the conflict of interest is known by
 the practitioner. The confirmation may be made
 within a reasonable period after the informed
 consent, but in no event later than 30 days.
    
    
        
        (c) 
         Copies of the written consents must be
 retained by the practitioner for at least 36
 months from the date of the conclusion of the
 representation of the affected clients, and the
 written consents must be provided to any officer
 or employee of the Internal Revenue Service on
 request.