Here’s some text you will be seeing if you get any emails from your EA or CPA (and will probably be in every tax article you read):
This opinion is limited to the one or more Federal tax issues addressed in the opinion. Additional issues may exist that could affect the Federal tax treatment of the transaction or matter that is the subject of this opinion and the opinion does not consider or provide a conclusion with respect to any additional issues. With respect to any significant Federal tax issues outside the limited scope of this opinion, the article was not written, and cannot be used by the taxpayer for the purpose of avoiding penalties that may be imposed on the taxpayer.
As a professional tax preparer, I’m governed by Circular 230 [link is to the revised rules for Circular 230 that go into effect on June 15th and requires Adobe reader]. New rules, in Sections 10.35-10.37, govern what I must state whenever I send a client a “limited opinion.” According to several attorneys lecturing at the SuperSeminar, an email to a client is considered a limited opinion. Under the new rules, the language (above, in bold) must be used. It must be in bold, and in a font larger than the other text (since I use, in general, text [non-html] email, neither bold nor a larger font is possible).
This is mothering taken to the extreme.
While the intent is good—the IRS naturally wants people to pay their taxes—this will end up like The Boy Who Cried Wolf. It will soon be ignored.
Now, for material opinions, a whole other standard applies. This applies (basically) to the Big 4 accounting firms and some law firms.
Anyway, now you know my feelings about this.