id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-1851	Shepard, Ira; McMahon, Martin	Recent Developments in Federal Income Taxation: The Year 2003	2022	130	.pdf	application/pdf	67899	3048	53	New proposed amendments to circular 230 differ from the 1/12/01 proposed amendments in several ways: (1) § 10.33 prescribes best practices for all tax advisors; (2) § 10.35 combines and modifies the standards applicable to marketed and more likely than not tax shelter opinions from former §§ 10.33 and 10.35; (3) § 10.36 contains the revised procedures for ensuring compliance with §§ 10.33 and 10.35; and (4) new § 10.37 contains provisions relating to advisory committees to the Office of Professional Responsibility. 0 The regulations turn on their head these interpretations of §§ 162, 261, and 263 by the Supreme Court.	cache/ftr-1851.pdf	txt/ftr-1851.txt