Circular 230 tenets certainly should be admonished when you undertake writing a tax advisory opinion letter. But the IRS guidelines does not explicitly detail the elements of such an undertaking. Allow me to share my approach.
First, I do not write tax advisory opinion letters to promote ventures or where I may be found to have a conflict of interest. The courts take a dim view of the independence of such opinions as well. That being said, allow me to share my format. Chime in with your two cents so this issue may be publicly vetted.
I am a tax planner. I do not prepare the tax returns of taxpayers who benefit from my tax advisory opinion letters. The purpose of the tax advisory opinion letter is to provide Read more