Tax Compliance After TEFRA: Dealing with the New Reporting Requirements and Penalties |
Common terms and phrases
abusive tax shelters addition to tax adequate disclosure advise AICPA amendments to Circular American Bar Association applicable attorney audit Canon carrybacks Circular 230 Amendments client conduct corporation counsel deductions determined disclosed due diligence ethical faith Federal tax aspect filed Formal Opinion 346 important Federal tax imposed income tax Internal Revenue Code Internal Revenue Service investors material tax issues ment Model Code negative opinion nonrecourse debt offering materials opin Original Circular 230 paragraph partnership plan or arrangement practitioner's Professional Responsibility promotion proposed amendments proposed regulations proposed rule reasonable basis relevant facts rely respect revenue procedure Revised Circular 230 Revised Opinion 346 standard substantial authority substantial understatement supra tax advisor tax law tax lawyer tax liability tax practitioners tax return tax shelter items tax shelter offering tax shelter opinion tax treatment taxable taxpayer TEFRA tion transaction Treasury Department underpayment understatement of tax violation waived