The Circular 230 Deskbook: Related Penalties, Reportable Transactions, Working Forms is an essential compliance resource for every tax professional who practices before the IRS, helping practitioners comply with complex Circular 230 amendments more easily while avoiding costly penalties and sanctions. This practice guide shows you how to meet mandated duties applicable to six types of covered opinions, comply with critical requirements for written tax advice, carry out prescribed duties when advising in preparation of tax returns, satisfy reporting/list maintenance rules for six types of reportable transactions, and qualify for ”safe harbors” that free you from burdensome Circular standards, exploit proven defenses against the Code’s section 6662 penalties, and avoid common errors that can trigger these 6662 penalties.

The new release includes the following updates:

• Chapter 1, Deference: When the Court Must Yield to the Government’s Interpretation, discusses a D.C. Circuit Court decision ruling in favor of the taxpayer after noting that the regulation in question was amenable to both a pro-taxpayer and pro-IRS reading and that the IRS itself had previously agreed with the taxpayer’s reading.
• Chapter 4, Circular 230, advises that the IRS and Treasury issued proposed amendments to various sections of the Circular in late December 2024. The proposal is driven, in large part, by losses the IRS sustained in two cases (Loving v. IRS and Ridgely v. Lew) limiting its authority under the statute that authorizes the promulgation of the Circular.

The Table of Authorities have also been updated.

Order a print copy today.

PLI PLUS subscribers can access this title through their subscription.