Aug. 31, 2013
Tax opinion just might make or break the case
Does an opinion get you out of penalties if the IRS disagrees with your treatment? It depends.
Robert W. Wood
Managing Partner
Wood LLP
333 Sacramento St
San Francisco , California 94111-3601
Phone: (415) 834-0113
Fax: (415) 789-4540
Email: wood@WoodLLP.com
Univ of Chicago Law School
Wood is a tax lawyer at Wood LLP, and often advises lawyers and litigants about tax issues.
When clients think about a legal opinion, they may imagine that a one-line email should suffice. Perhaps that is a wake-up call to all attorneys who send frequent and cryptic emails to our clients! When lawyers talk about a legal opinion, they are generally discussing a formal and thoroughly cited letter. These heavy opinion letters are required in many transactions.
For example, a buyer in a corporate transaction needs a legal opinio...
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