David T. Moldenhauer
Clifford Chance US LLP; New York Law School
LEGAL OPINION LETTERS, A COMPREHENSIVE GUIDE TO OPINION LETTER PRACTICE, Sterba, ed., Aspen Publishers, Inc.
This paper will constitute the forthcoming chapter on tax opinions in Legal Opinion Letters (Sterba ed., Aspen Publishers, 3d ed.). It addresses: (1) the need for and functions of tax opinions, (2) the sources of authority regarding tax opinions, (3) the tax shelter reporting and list maintenance rules affecting tax opinions, (4) the taxpayer penalties affecting tax opinions, (5) who may prepare tax opinions, (6) to whom a practitioner has duties when preparing tax opinions, (7) the confidentiality of tax opinions, (8) taxpayer planning opinions, (9) tax return position opinions, (10) tax penalty protection opinions, (11) tax opinions relating to financial audits, and (12) tax shelter marketing opinions.
Number of Pages in PDF File: 37
Keywords: Tax, Legal Ethics, Circular 230
JEL Classification: K34
Date posted: February 22, 2007