Title

Tax Practice in a Circular Revolution: A Review of PLI's Circular 230 Deskbook

Document Type

Article

Comments

Real Property, Probate and Trust Journal, Spring 2007

Abstract

This short review essay evaluates the Practicing Law Institute's Circular 230 Deskbook by Jonathan G. Blattmachr, Mitchell M. Gans and Damien Rios. For attorneys, accountants and others who "practice" before the IRS, the Circular 230 Deskbook is a masterful analysis and an important guide to the Internal Revenue Service's labyrinthine rules and regulations governing tax penalties, reportable transactions and the conduct of tax practitioners.

Most tax attorneys and accountants have reacted to the recent changes to Circular 230 by appending banner notices to all written communications. Without fully understanding the underlying rules, however, a practitioner cannot be sure that a banner alone will guarantee compliance with Circular 230's requirements. If Sir Walter Raleigh claimed that there is nothing new in the human experience because the world "hath ever been in a circular revolution," tax practice in the twenty-first century surely must be an exception. The complex rules of Circular 230 have transformed the very nature of tax practice and likely will continue to govern it for the foreseeable future. For that reason, every tax professional must become fully conversant with the details of Circular 230, or else risk public censure, suspension, fines or even the end of one's professional career. The PLI Circular 230 Deskbook provides a comprehensive, complete and analytical examination of the topic. Of particular interest to practioners will be the five interpretative charts in the book's Appendix that are reprinted as colored, glossy, single-reference sheets that can be removed from the book.

Date of Authorship for this Version

October 2006

Keywords

Circular 230, Internal Revenue Service, reportable transactions, lawyers