With the tax law becoming increasingly complex, it is no surprise that there often can be several well-intentioned interpretations of a particular provision. Also no surprise is the expectation of many clients that a fee for planning advice should almost always result in an exponential decrease in overall tax liability.
Add to this mix an Internal Revenue Service commissioner who is very vocal about the need for direct enforcement efforts against practitioners who facilitate overly aggressive tax planning, and sparks begin to fly. There is much room for misinterpretation among IRS personnel and practitioners as to what goals legitimate tax planning can embody without sparking litigation.
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