A Tax Opinion

September 1, 2012 | By Keith Martin in Washington, DC

A tax opinion cannot be relied on to avoid IRS penalties if the lawyer writing the opinion helped promote the transaction and receives fees that are tied to the tax benefits produced. The conflict of interest makes the opinion unreliable, the US Tax Court said in SAS Investment Partners v. Commissioner in June.

NewsWire Editor

Keith Martin
Partner, United States
Washington, DC
Email
T: +1 202 974 5674

Download PDF of the NewsWire

Stay Connected

Subscribe by Email