Covered Opinion

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Pre-written Papers:

Title: Covered Opinion

Essay Details:

Subject: Business

Author: Laura R

Date: July 15, 2014

Level: University

Grade: A

Length: 2 / 356

Essay text:

(1) The main reason most taxpayers obtain opinion letters from the tax professionals is the good faith and reasonable basis defense against the accuracy related penalties. (2) The opinion letter must provide the practitioner’s opinion as to the likelihood that the taxpayer will prevail on the merits for all significant federal tax issues, and must also provide the practitioner’s overall conclusion that the tax treatment of the relevant transaction is the proper treatment. Generally, if the practitioner fails to reach a conclusion at a confidence level of more likely than not, the favorable opinion should not be granted or prominent disclosure should be included...

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