[IMGCAP(1)]Clients have been confused by e-mails from their accountants to set a lunch meeting that include a warning, often highlighted in bold font and upper case letters, that the invitation could not and should not be considered tax advice and could not be relied upon to avoid penalties. This ritualistic inanity began about five years ago when the service issued new final regulations under Circular 230 relating to “Written opinions.”

Since some e-mails -- and for these purposes an e-mail is considered writing -- a practitioner or firm sent clients would include some tax opinion or advice, there would be a written reliance opinion (as that term was defined) that was required to follow certain prescriptions, unless -- and of course every practitioner made use of this safe harbor -- the e-mail contained a legended disclaimer as to the reliability of the tax advice.

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