In what is candidly referred to in the Preamble as an effort to “. . . replace rigid rules for written tax advice with more flexible rules and eliminate the necessity to provide disclaimers in certain written tax advice. . .,” the final regulations issued under T.D. 96681 “. . . reduce the burden imposed on small entities that issue written tax advice.” The final regulations follow proposed regulations which were issued on September 17, 2012.2 In general, the final regulations are expected to be welcomed by tax practitioners as a step toward more reasonable rules for providing written advice to clients and others.



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