IRS Circular 230 Regulations for Written Tax Advice

The Internal Revenue Service ("IRS") has adopted tax practice regulations (Circular 230) for attorneys, accountants and IRS-enrolled agents ("tax practitioner(s)") applicable to the issuance of certain written tax advice. The regulations, which became effective June 21, 2005, set forth not only "aspirational best practices" applicable to all tax practitioners, but also provide mandatory requirements for tax practitioners who provide so-called "Covered Opinions." These rules are enforced by important sanctions relating to practice before the IRS. The regulations do not alter or supplant other ethical standards applicable to tax practitioners.

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