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Smith, a staff accountant, drafted on September 14, The letters are based on the facts for practice research. Before reviewing this web page, we recommend that you study the client letter lessonread the facts for practice researchcomplete the research, and attempt to formulate a letter for both Fly Jones, the professional basketball player, and Mr.
I appreciate the opportunity to advise you regarding this tax matter. To ensure a complete understanding between us, I am stating the pertinent information about the advice that I will be rendering and the facts you provided to me.
Responsibilities I use my judgment in resolving questions where the tax law is unclear or where conflicts may exist between the taxing authorities.
Unless you instruct me otherwise, I resolve such questions in your favor whenever possible. Thus, I cannot guarantee the outcome in the event the IRS challenges my opinion. You remain responsible for any tax or related liabilities resulting from an adverse IRS or judicial decision.
The law imposes various penalties when taxpayers understate their tax liabilities. Tax professionals also may be subject to penalties when an understated tax liability is based on a position that the professional recommends but has no realistic possibility of being sustained.
A realistic possibility of success exists if the tax professional has a good faith belief that the position has at least a 1 in 3 chance of being sustained on its merits if challenged.
Facts The following facts are based on your written correspondence to me dated June 2, If these facts are incomplete or incorrect, please let me know right away. You are a U. To discourage laziness and mental errors, your teammates formed the Slammin-Jammin Club on August 30, Membership in the club was voluntary, but every Wildcat joined.
When a Wildcat was responsible for a turnover e. The rest of the funds, again according to previously-determined club rules, were given to the American Red Cross. The Red Cross knew nothing about the contribution until it occurred on May 12, One month later, the American Red Cross sent individual letters of thanks and receipts to each member of the club.
You itemize deductions and file jointly. Conclusions and Recommendation Based on our research, you can deduct most of the fines you paid to the Slammin-Jammin Club as a charitable contribution since they are in the nature of gifts per Duberstein, a Supreme Court decision.
In this judicial case, the taxpayer received a Cadillac in return for periodically giving names of potential customers to a business associate.
Similarly, you intended to make a gift to the American Red Cross.The letters are based on the facts for practice research. Before reviewing this web page, we recommend that you study the client letter lesson, read the facts for practice research, complete the research, and attempt to formulate a letter for both Fly Jones, the professional .
The Demand Letter. Relying on the evidence so far, your attorney will write a letter demanding what she believes is a fair settlement amount. Because a demand letter becomes part of negotiations, your attorney will demand the maximum amount she believes a jury might award.
I am providing this letter on behalf of my clients in response to your request for a legal opinion as to the following matters. We are of the opinion that under the Arizona law.
distinctive characteristics of traditional legal-writing style. But you ought to banish them from cli-ent letters. Simply put, do not use traditional legal writing style when writing to clients.
Try not to sound like a lawyer. That’s a chal-lenge because legalisms abound in . Template LEGAL OPINION This is a sample legal opinion for the purpose of paragraph (A) of Part A (Initial Conditions Precedent) of Schedule 1 (Conditions Precedent) to the Contract for Difference Standard Terms and Conditions.
It is issued by the CfD Counterparty as guidance. Writing Client Letters. Tax professionals differ in their approaches to client letters. This lesson briefly discusses a few issues that professionals should consider to assure that the client letter is effective in communicating research findings and conclusions.