"Any tax advice included in this written or electronic communication was not intended or written to be used, and it cannot be used by the taxpayer, for the purpose of avoiding any penalties that may be imposed on the taxpayer by any governmental taxing authority or agency." (Proposed Circular 230 disclaimer language from Deloitte.)Going forward, tax clients across the country, whether they seek advice from a Big Four Firm, a tax attorney or even a sole practitioner, can expect to see disclaimers like this accompanying all correspondence and written advice.
In December 2004, in a climate suffused with the repercussions from Enron and some very visible abusive tax shelters, the Internal Revenue Service issued final regulations relating to Circular 230, the rules that govern those who practice before the agency. These rules cover accountants, attorneys, enrolled agents and enrolled actuaries. The new regulations became effective in June 2005, and the visible effects are starting to turn up everywhere.
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