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No Joke: Circular 230 is Here to Stay

7 Pages Posted: 1 Mar 2007  

Dennis J. Ventry Jr.

University of California, Davis - School of Law


In the wake of a new American Bar Association formal opinion covering tax shelters and a recently enacted suite of anti-shelter statutory penalties in 1982, many observers believed that the Treasury Department would withdraw its proposed amendments to Circular 230 covering legal opinions used in the promotion of tax shelters. They were wrong. Treasury stayed the course. It issued modified proposed regulations in 1982 and final regulations in 1984. Throughout the process, Treasury absorbed input from the practitioner community. And it complemented Congress's continued efforts to curb tax shelter activity with additional rounds of new and strengthened statutory penalties. By the mid-1980s, the Treasury Department and Circular 230 had become the catalyzing force of a coordinated and aggressive anti-shelter effort.

Suggested Citation

Ventry, Dennis J., No Joke: Circular 230 is Here to Stay. Tax Notes, Vol. 111, p. 1409, June 19, 2006. Available at SSRN:

Dennis Ventry (Contact Author)

University of California, Davis - School of Law ( email )

UC Davis School of Law
400 Mrak Hall Drive
Davis, CA 95616-5201
United States
530-752-4566 (Phone)

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