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Checklist for Covered Opinions and Other Written Advice About Federal Tax Issues
The Circular 230 Deskbook: Related Penalties, Reportable Transactions, Working Forms
Book Publication Date:
It is recommended that a Practitioner consider going through this 27-part checklist before sending out written advice with respect to any federal tax issue and consider fully the consequences of any question answered by checking a boldfaced/underlined box.
PLI Item #:
"Checklist for Covered Opinions and Other Written Advice About Federal Tax Issues"
"protect the client from tax penalties"
"Federal tax issue"
any unreasonable favorable resolution
Limited Scope Opinion
section 10.35(e) of the Circular
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