Regulation of Tax Practice, 2010
This new title is one of seven releases in the LexisNexis Graduate Tax Series. Like all books in the Graduate Tax Series, Regulation of TaxPractice was designed from the ground-up with the needs of graduate tax faculty and students in mind. This book differs from others in the Graduate Tax Series by focusing on primary source materials other than the Code, regulations and judicial decisions rendered by federal judges. There are a wide array of sources governing the practice of tax law, including State ethics rules and opinions, rules of court, and state judicial opinions that are as significant in the regulation of tax practice as provisions of the Code (e.g., return preparer penalties in Section 6694) and Regulations. Ethics rules governing accountants who provide tax services are relevant to those who concurrently maintain professional licenses as lawyers and accountants, and also serve as nonbinding guidance to non-accountant lawyers who practice in the tax area, also are important.
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Introduction THE TAX LAWYERS DUTY TO THE SYSTEM
SOURCES OF PROFESSIONAL REGULATION
TAX RETURN PREPARATION AND ADVICE
TRANSACTIONAL PLANNING AND ADVICE
Rules Applicable to Diacﬁalinnry Proceeding 10
IOJ 100 may practice 5
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Adlman administrative adopted as subd advise AICPA amended American Bar Association appeal application appraisal attorney-client privilege audit Bar of California Birbrower certification Circular 230 client Code conclusion contingent fee corporation counsel Director disbarment disciplinary disclosed disclosure documents effective November 15 enrolled agent entity estate planning ethical facts federal tax ﬁled firm Hedge Fund income tax Internal Revenue Service involved issue jurisdiction law in California Law Judge lawyer lease litigation matter Model Rule opinion party Pascale penalty person practice law practice of law proceeding Professional Conduct Professional Responsibility protection purpose realistic possibility reasonable referral refund regulations relettered effective January relevant represent representation sanction Section solicitation SRTPs SSTS Statement on Standards substantial authority Supreme Court tax consequences tax law tax planning tax practice tax return position tax return preparer tax shelter taxing authority taxpayer Textron transaction Treasury trust law United violation work-product doctrine workpapers