Exploring Contingent Fee Tax Advice

Tax Analysts, in Tax Notes Today, has published an article, Exploring Contingent Fee Tax Advice.  The abstract is as follows:

Robert W. Wood and Donald P. Board discuss contingent fees in the context of Circular 230 and Ridgely, and they explore how to approach several contingent fee scenarios.

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IRS Memo SBSE-04-0517-0030: FAQs Not Legal Authority

In IRS Memo SSBSE-04-0517-0030, the IRS reminds its field auditors that FAQs do not constitute legal authority. Therefore, the Service can take a position that differs with its FAQs. The Memo, which also states that the Internal Revenue Manual will be amended to reflect this guidance, begins as follows:

The

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