What is Written tax advice standards?
In short
Circular 230 requires practitioners giving written advice on federal tax matters to base it on reasonable factual and legal assumptions, consider all relevant facts, avoid unreasonable reliance on others' statements, and relate the law to the facts.
Key takeaways
- The advice may not consider the chance that a return won't be audited or an issue won't be raised.
- The standard is reasonableness, considering all facts and circumstances.
- Practitioners can rely on others' advice only if it is reasonable and in good faith.
Where it's tested
REG: Circular 230 & Practitioner Ethics — study notes, a five-minute revision sheet and practice questions.
Practise: 3 questions
Question 1 of 3 · 0 answered
Under Circular 230 §10.37, when giving written tax advice, a practitioner must NOT: