Internal Revenue Bulletin:  2004-5 

February 2, 2004 

ADMINISTRATIVE


Table of Contents

T.D. 9106 T.D. 9106

Final regulations under section 7430 of the Code provide guidance to taxpayers on how to make a qualified offer. The regulations explain the circumstances under which qualified offers may be made, the requirements to make a valid qualified offer, and to whom the qualified offer should be made. The regulations also provide examples to aid taxpayer in understanding how qualified offers operate.

REG-122379-02 REG-122379-02

Proposed regulations under section 330 of title 31 of the Code set forth best practices for tax advisors providing advice to taxpayers relating to federal tax issues or submissions to the Internal Revenue Service and modify the standards for certain tax shelter opinions. Section 10.33 encourages all tax advisors to provide their clients with the highest quality representation. Section 10.35 prescribes specific requirements for “more likely than not” and “marketed” tax shelter opinions. Section 10.36 provides that the practitioner who has the principal authority and responsibility for overseeing a firm’s practice of providing advice to clients regarding federal tax issues must take reasonable steps to ensure that the firm has adequate procedures in place for purposes of complying with section 10.35. Section 10.37 authorizes the Director of the Office of Professional Responsibility to establish one or more advisory committees to review and make recommendations regarding profe ssional standards or best practices for tax advisors, including whether a practitioner may have violated section 10.35 or 10.36. A public hearing is scheduled for February 18, 2004.


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