Nuts and Bolts of ?Covered Opinions? Under Circular 230
Edward M. Manigault and Steve R. Akers
34 PROBATE& PROPERTY MARCH/APRIL 2006 If you have not yet scrutinized the recent changes to Circular 230, you should do so now. The “covered opinion” rules will change your tax practice, even if you do not prepare or file tax returns or negotiate or litigate against the IRS. Circular 230—The Basics If you have filed a Form 2848 (Power of Attorney and Declaration of Representative), then sections 10.2(e) and 10.3 of Circular 230 say that you are subject to Circular 230. Circular 230 provides the...