Article Title

Section 6694 Preparer Penalties and Tax Advice: The Latest on the Constantly Moving Target


ethics, tax opionions, business planning, estate planning

Document Type



Tax, business planning, and estate planning attorneys must be familiar with the ethical rules governing practice before the IRS, including the standards applicable to giving tax advice to clients. This paper will provide an overview of the recent changes to the tax advice rules in both the Internal Revenue Code and in Treasury Circular 230. These changes will have an impact on every lawyer practicing in business or estate planning, trust administration, or tax law. The paper will concentrate on the recent amendments to section 6694 and the new proposed regulations interpreting and applying those amendments.