id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-2802	Hodaszy, Steven Z.	Circular Argument: What is Wrong, and Right, with the Circular 230 “Covered Opinion” Regulations	2011	53	.pdf	application/pdf	28628	1310	51	There has to be some meaningful regulation of tax shelter opinions; otherwise, experience indicates that too many practitioners will be enticed by market forces to render unsound opinions in support of illegitimate shelters. Prior to the Covered Opinion Regulations under Circular 230, the only professional ethical guidance to attorneys specifically in relation to tax shelter opinions was found in the American Bar Association’s Formal Opinion 346, which was released in 1982.	cache/taxlaw-2802.pdf	txt/taxlaw-2802.txt