The Circular 230 Deskbook is an essential compliance resource for every tax professional who practices before the IRS.  It helps practitioners comply with complex Circular 230 amendments more easily — and avoid costly penalties and sanctions.  In addition to demonstrating prescribed duties when advising clients in the preparation of tax returns, it offers laminated, quick-reference compliance tools.

This thirty-second release updates the treatise with the latest developments in tax and estate law relating to IRS Circular 230.   Highlights from the new release include:

• Chapter 1, Section 1:3: Discusses Wilson v. Commissioner, a case concerning whether the IRS’s “publicly stated positions” in the IRS manual or instructions “constitute rules carrying the force of law as required for Chevron deference.”
• Chapter 3, Section 3:5: Explains whether the Anti-Injunction Act would preclude pre-enforcement judicial review if Congress amended the disclosure rules to impose a tax on a reportable transaction rather than a disclosure obligation backed up by a penalty for those who fail to comply.
• Chapter 4, Section 4:13.6[B]: Explores Rodgers v. United States, in which the Ninth Circuit decided whether willfulness for purposes of section 6694(b) can be predicated on the basis of willful blindness or if it must be based on a finding of specific intent to understate liability.
• Updated Appendix N, IRS Form 2848, Power of Attorney and Declaration of Representative.
• Updated Table of Authorities is included.

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