Kip Dellinger has published an article on Tax Notes, Tax Advice and Reliance: Potholes for the Tax Professional (July 10, 2017). The summary is as follows:
In this article, Dellinger points out that although the confidence thresholds for avoiding a penalty are uniform, courts and regulators of tax practice often treat them differently in evaluating the tax practitioner’s standard of care. He argues that practitioners should therefore consider not only the statutory requirements for a tax position, but also the possible consequences that may arise from that position.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.