Friday, March 2, 2007
David.Moldenhauer (Clifford Chance, New York) has posted Tax Opinions, in Legal Opinion Letters: A Comprehensive Guide to Opinion Letter Practice (M. John Sterba, Jr., ed.) (Aspen, 3d ed. 2007). Here is the abstract:
This paper ... addresses: (1) the need for and functions of tax opinions, (2) the sources of authority regarding tax opinions, (3) the tax shelter reporting and list maintenance rules affecting tax opinions, (4) the taxpayer penalties affecting tax opinions, (5) who may prepare tax opinions, (6) to whom a practitioner has duties when preparing tax opinions, (7) the confidentiality of tax opinions, (8) taxpayer planning opinions, (9) tax return position opinions, (10) tax penalty protection opinions, (11) tax opinions relating to financial audits, and (12) tax shelter marketing opinions.