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Checklist for Covered Opinions and Other Written Advice About Federal Tax Issues


Book Publication Date: Mar 2020
Description: 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.
Type: Checklists
PLI Item #: 41586
Practice Area: Tax
Keywords: "Checklist for Covered Opinions and Other Written Advice About Federal Tax Issues"; "Covered Opinion"; "protect the client from tax penalties"; Listed Transaction; "tax avoidance"; "Federal tax issue"; any unreasonable favorable resolution; Limited Scope Opinion; promoter relationship; section 10.35(e) of the Circular; Marketed Opinion

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