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Elements of Opinion Letters
Legal Opinions on Corporate Matters
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2d Cir ABA Accord ABA/ACREL agreement in question American Bar Association application assets attorney au.t authority bankruptcy choice of law Circular 230 client conflict of laws contract Corp corporation Director of Practice disharment enforceability enrolled agent enrollment executed and delivered execution and delivery factual Federal tax issues filed Foreign Bank foreign counsel foreign law forum selection clause full paragraph governing law clause Gruson hefore the lnternal Internal Revenue Code Internal Revenue Service jurisdiction law firm laws rules liability limited lnternal Revenue Service Loan obligations opining lawyer opinion letter opinion recipient Opinion Report practice hefore practitioner Proc proposed regulations public policy qualification Real Estate reasonahle rely remedies opinion rendered representation request respect revenue procedure securities statement stipulated law Supp tax shelter item tax shelter opinion taxpayer third party tion Transaction Documents valid violation York counsel York law