In 2005, the Internal Revenue Service finalized substantial revisions to Circular 230 governing the rules for practice before the IRS. The revisions were in response to what was believed by the IRS to be improper practices in the preparation of tax opinions in support of tax-sheltering transactions. The IRS believed that tax practitioners were relying in their opinions on statements and representations from the tax shelter promoters that they knew or had reason to believe were not accurate.
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