Hired gun tax attorneys have fired their last bullet, and the sheriff has arrived in town.
A (worthless) tax attorney's opinion is behind most all tax frauds.
An extremely lucrative piece of legal work when one short letter can help tax sham operators sells tax
shelters in the $100's millions.
"Many opinion letters about tax-motivated transactions are basically worthless," says David Hariton,
a tax partner at law firm Sullivan & Cromwell in New York. "They hide the ball within a matrix
of boiler-plate recitations of complex regulations, but when you cut through all of the cant, what
they really say is, 'this will work, unless it doesn't.' "
Jenkens & Gilchrist to Close its Doors Due to Tax Shelter Work
IRS Abusive tax schemes
Report Abusive tax schemes
Gimme Shelter, CBS 60 Minutes
Tax attorneys taken down one of largest law firms
Note:
In spite of all of these recent events people blindly accept tax attorney opinions as the gospel.
Investment bankers and advisor often mention a tax attorney's opinion clearing a tax scheme,
to give clients a false sense of confidence in the scheme. Although a good honest tax attorney
usually gives sound advice, they will inform the tax payer that a tax attorney's opinion
carries no weight with the IRS. The only weight a tax attorney's opinion carries is with the SEC
when considering negligence on the part of the investment banker or advisor in a wrongful tax case.
The investment bankers and advisor hire the tax attorneys for both their own protection and to
give false confidence to potential clients.
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