Sec. 1033 Best Practices for Tax Advisors
Tax advisors should provide clients with the highest quality representation concerning federal tax issues in providing advice and IRS submissions. Best practices include:
1. Communicate clearly with client regarding terms of engagement, including: determine client’s expected purpose;
2. Establish the facts, determining which facts are relevant, evaluating the reasonableness of any assumptions or representations, relating the applicable law to the relevant facts and arriving at a conclusion supported by the law and the facts (emphasis added);
3. Advising the client regarding the impact of conclusions reached; and
4. Acting fairly and with integrity in practice before the IRS.