Clients increasingly show up with tax positions backed by blog posts, podcasts, social media, and AI, but how much of that actually counts? Jeremy walks through the closed list of sources the regulations recognize as authority, from the Code and Treasury regulations to court cases and revenue rulings, and explains why IRS publications, form instructions, and even other tax professionals’ opinions don’t make the cut. He also covers how to weigh supporting and contrary authorities against each other, and why that matters for the Section 6662 substantial understatement penalty.
Connect with Jeremy
https://www.linkedin.com/in/jwellstax
https://www.steadfastbookkeeping.com
Subscribe on YouTube
https://www.youtube.com/@TaxinAction
Earn CPE for Listening to This Podcast
https://www.earmark.app/
This podcast is a production of Earmark Media
Sponsors
Thomson Reuters - http://taxshow.promo/taxautomation
Thomson Reuters - http://taxshow.promo/taxautomation
- (00:00) - Client Research Challenge
- (01:42) - Episode Roadmap
- (05:50) - Circular 230 Framework
- (10:20) - Substantial Understatement Basics
- (15:43) - Avoiding the Penalty
- (17:48) - Confidence Standards
- (24:50) - What Counts as Authority
- (36:18) - Non Authority Sources
- (38:06) - Disclosure and Forms
- (42:29) - Diligent Research Workflow
- (45:22) - Donna Case Study
- (52:06) - Conclusion and Next Steps
Connect with Jeremy
https://www.linkedin.com/in/jwellstax
https://www.steadfastbookkeeping.com
Subscribe on YouTube
https://www.youtube.com/@TaxinAction
Earn CPE for Listening to This Podcast
https://www.earmark.app/
This podcast is a production of Earmark Media