Statements and Submissions
Last updated February 2005
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Comments Concerning Notice 2004-80 (Interim Guidance Under IRC §§ 6111, 6112 and 6708)*
Submitted to the Internal Revenue Service in February 2005.

Comments on the National Taxpayer Advocate's Practitioner Licensing Proposal*
Submitted to the Internal Revenue Service in February 2004.

Comments Regarding Proposed Revisions to Circular 230*
Submitted to the Internal Revenue Service on behalf of the ABA Section of Taxation in February 2004.

Comments Concerning the Advance Notice of Proposed Rulemaking Relating to Revising Circular No. 230 to Address Standards of Practice Before the Internal Revenue Service*
Submitted to the Internal Revenue Service in March 2003.

Comments Concerning Proposed Revisions to Circular 230*
Submitted to the Internal Revenue Service on behalf of the ABA Section of Taxation in April 2002.

Comments Regarding Proposed Amendments to the Regulations Governing Practice Before the Internal Revenue Service (Title 31, Code of Federal Regulations, Subtitle A, Part 10)
Submitted to the Internal Revenue Service on behalf of the ABA Section of Taxation in April 2001.

Statement 2000-1
This standard addresses whether differences between the income tax return accuracy standards for taxpayers and the lawyers who advise them result in conflicts of interest between clients and their lawyers. Specifically, this standard explores whether the benefits of adequately disclosing return positions, which may affect taxpayers and advisers differently, generate conflicts of interest.

Also available in an 8-page printer-friendly version.*

Comments Regarding "Pre-Opinion Opinions" Relating to Corporate Tax Shelter Items
Submitted to the Internal Revenue Service on behalf of the ABA Section of Taxation in September 2000.

Comments on Notice of Proposed Rulemaking to Amend the Regulations Governing Practice Before the Internal Revenue Service ("Circular 230" Sections 10.7 and 10.28)
Submitted to the Internal Revenue Service on behalf of the ABA Section of Taxation in September 2000.

Statement 1999-1
This Statement addresses the issue of counsel’s responsibilities upon discovering a computational error made by the Internal Revenue Service in the client's favor that is unrelated to any affirmative representation or omission of either the client or counsel.

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