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Sample Memorandum of Written Advice Not Constituting a Covered Opinion
The Circular 230 Deskbook: Related Penalties, Reportable Transactions, Working Forms
Book Publication Date:
Sample Memorandum of Written Advice Not Constituting a Covered Opinion from attorney/tax advisor to client
Other Document Templates
PLI Item #:
"Sample Memorandum of Written Advice Not Constituting a Covered Opinion"
"Statement About Circular 230"
Federal tax issue
requirements of the Circular
principal purpose of the transaction
section 10.35 of the Circular
Opinion Issued under Conditions of Confidentiality or Opinion with Contractual Protection
tax avoidance or evasion
Limited Scope Opinion
No Duty to Advise You of Change in the Law
applicable judicial tax doctrine
section 6662 of the Internal Revenue Code of 1986
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