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Tax

Jul. 4, 2000

Audit Roulette

THE ADVISER: Tax Law By Menasche M. Nass and Andrew Bernknopf Promoters of the latest generation of tax shelters, newly named "tax products," are aggressively marketing to businesses and their owners. One day, a client may call to seek advice about one of these tax products. In all likelihood, the client already will have a legal opinion from the shelter's promoters. The legal opinion may even conclude that the desired tax result "should be" or is "more likely than not to be" sustained. With opinion in hand, the client may then just seek counsel's general business advice about the tax shelter, rather than a technical, legal analysis.

By Menasche M. Nass and Andrew Bernknopf
        Promoters of the latest generation of tax shelters, newly named "tax products," are aggressively marketing to businesses and their owners. One day, a client may call to seek advice about one of these tax products. In all likelihood, the client already will have a legal opinion from the shelter's promoters. The legal opinion may even conclude that the desired tax res...

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