IRS Circular 230 Notifice
 
To Promote Ethical Practice by Tax Professionals
 
Severe penalties may be imposed on a firm and its professionals for failure to comply with these new regulations. . . the significance of the legend is that the client may not avoid an accuracy-related penalty (such as for negligence or a substantial understatement of tax) based on reliance on our advice if the tax treatment discussed in our advice is not sustained. Other defenses to a penalty may still be asserted, such as the existence of substantial authority that supports the position.

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IRS CIRCULAR 230