How to Write a Tax Advisory Opinion Letter

Financial accounting is historic in perspective while managerial accounting is prospective in perspective. Similarly, tax return preparation is historic in perspective while tax planning is prospective in perspective. The tax advisory opinion letter serves the tax planning function by documenting the current state of law, regulations, administrative rulings, and decisional law in support of planned activities. The tax advisory opinion letter set forth in this webcast borrows its design from well established appellate brief writing practices. This webcast involves Section 179 depreciation expense at the partnership level in a startup operation. Although not incorporated into this webcast, Dr. Jenkins wants to share his paper, "Why Section 179(b)(3)(A)'s Business Income Limitation Does Not Apply to Partnerships or S Corporations." The paper is currently in peer review at a university tax journal. Also, the ACPEN/BPN webcast based on this paper will be first aired during the week of September 25-29, 2017. Please be sure to look for that announcement and register for the webcast. Syllabus Lesson 1. Introduction Lesson 2. Tax Advisory Opinion Letter - Introduction Lesson 3. Tax Advisory Opinion Letter - Facts Lesson 4. Tax Advisory Opinion Letter - Issues Lesson 5. Tax Advisory Opinion Letter - Discussion Lesson 6. Tax Advisory Opinion Letter - Conclusion Lesson 7. Tax Advisory Opinion Letter - Acknowledgement of Factual Verity