Tax Advice & Written Tax Opinions for Taxpayers
Taxpayers often require tax advice to either report certain transactions on their tax returns or to understand the tax ramifications for particular transactions.
In many cases, this tax advice relates to large, and usually, once in a lifetime time transactions, such as the sale of a business or real estate, business or non-profit transactions, employee benefits, or trust and transfer tax issues.
This type of tax advice can be rendered by a tax attorney orally or in writing. Reliance on oral tax advice from a tax practitioner generally will not relieve the taxpayer from IRS-imposed accuracy related penalties if the transaction in is discovered and challenged by the IRS.
Reliance on certain types of written advice from a tax attorney may relieve the taxpayer from IRS-imposed accuracy related penalties. The IRS has promulgated a number of rules for what types of written advice from a tax attorney qualifies for this type of treatment (and it proscribes sanctions for tax practitioners who do not comply with the IRS rules).
Our firm frequently provides tax advice and written tax opinions for clients on significant and complex federal and state tax matters.
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