I speak at numerous conventions and conferences, and attendees sometimes contact me for additional information about abusive tax shelters and Circular 230.Among other things, Circular 230 sets forth the requirements for disclosure of certain tax shelter transactions by tax professionals. Regulations also impose new obligations on tax professionals, and on taxpayers engaged in any kind of tax-avoidance transaction.

While it might not be the clear intent of Congress or even of the Internal Revenue Service to extend these disclosure obligations to include transactions at least arguably sanctioned by the Internal Revenue Code, there is enough ambiguity in the new regulations to cause many tax advisors and preparers to disclose transactions that may be doubtful.

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