The Circular 230 Deskbook is an essential compliance resource for every tax professional who practices before the IRS, helping practitioners comply with complex Circular 230 amendments more easily — and avoid costly penalties and sanctions. This treatise was recently updated to include analysis of the latest developments in tax and estate law relating to IRS Circular 230 including the following:

• Discussion of conflicting 2020 decisions on whether a penalty under section 6707A is void if the IRS notice designating the transaction as a listed one is issued without notice and comment in violation of the Administrative Procedure Act (Michigan) or if that argument can only be pursued in a refund action (Arizona) (See Chapter 1 and Chapter 3).
• Examination of the difference between the “substantial authority” (having a 40% chance of success on the merits) and “reasonable basis” (where a taxpayer cannot be found negligent if its tax position has a 20% chance of success on the merits) standards under section 6694 (See Chapter 4).

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