Tax Opinions and Other Tax Advice — Preparation, Use and Reliance (Portfolio 619)


Joseph Erwin


Law Office of Joseph M. Erwin

At a glance


Bloomberg Tax Portfolio, Tax Opinions and Other Tax Advice — Preparation, Use and Reliance, No. 619, describes the legal and ethical standards and practical principles for preparation of opinions about United States federal tax issues. It focuses on the duty of persons that provide written advice on tax issues that may be reported on tax returns submitted to the IRS. The Portfolio does not address duties solely related to the preparation of tax returns though some rules applicable to tax return preparation are analyzed to the extent they apply to the authors of tax opinions.

The overriding authority of Circular 230 in the format and content of tax opinions is analyzed. The application of evidentiary privileges to tax opinion preparation, the hierarchy of legal authorities and their weight in reaching a conclusion, and the various types of written advice are described.

The information contained in this Portfolio is provided on the understanding that it does not constitute legal, accounting, or other professional advice or services, and that the publisher and author expressly disclaim any liability for alleged damages resulting from reliance on this information.

This Portfolio may be cited as Erwin, 619 T.M., Tax Opinions and Other Tax Advice — Preparation, Use and Reliance.

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