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.

See full Continue reading

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:


Continue reading