Tax
Mar. 5, 2026
They actually put that in writing? Common mistakes in written tax advice - Part I
Casual emails, recycled opinions, and unchecked client facts can turn routine tax advice into Circular 230 violations, penalties, malpractice claims and career-ending discipline.
Sharyn Fisk
Tax Attorney
Willkie Farr & Gallagher LLP
Federal and State Tax Controversy Matters
Every tax practitioner has seen them--the tax opinion letters that make you wonder what the author was thinking when they put that in writing. Perhaps it's the confident "more-likely-than-not" conclusion resting on cherry-picked authorities and wishful thinking. Maybe it's the boilerplate analysis recycled from a 2019 opi...
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