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Tax Blawg

Tax Talk Blog for Tax Pros

Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.

Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.

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Posts tagged opinion letter.

We now tackle the third question raised by our original post about Canal Corp. v. Comm’r: when (if at all) should courts defer to the opinion of a reputable tax advisor in deciding whether to uphold an assessment of penalties against a taxpayer?

To be clear, deference in this context does not mean that courts should defer to an advisor’s opinion regarding the substantive merits of a transaction.  If penalties are at issue, the substantive merits (or lack thereof) of a transaction have already been decided.  Instead, deference in this context refers to whether courts should presume that a taxpayer's receipt of an opinion written by a reputable advisor is sufficient to avoid the imposition of penalties on a transaction, notwithstanding a perceived conflict of interest on the advisor's part.