Circular 230: An Overview

First Published in the:
Journal of Tax Practice and Procedure

December 2005-January 2006

© 2006 D. Brager*, C. Cobb, K. Dellinger and W. Quealy, Jr.

The written advice and best practice standards added  to the Circular 230 regulations have generated considerable comment since they were first proposed at the  end of 2003. In the meantime, the Office of Professional  Responsibility (OPR) has virtually doubled in size during  2004 and 2005, and OPR management has indicated  that the Office intends to increase enforcement through  disciplinary actions against practitioners subject to Circular 230 in other areas of required compliance under  the Circular. The purpose of this article is two-fold. The  first is to review the new written advice and best practice  standards. The second is to look at Circular 230 more  generally and review some of the practice standards on  which the OPR appears to have focused.

Read Circular 230:  An Overview [PDF]


*Dennis Brager, Esq., is a State Bar Certified Tax Specialist in Los Angeles. A former IRS senior trial attorney, Mr. Brager now devotes his efforts exclusively to helping clients resolve their tax problems with the IRS and California State tax agencies. Services include negotiating Tax Debts, Tax Fraud Representation, Tax Litigation, Tax Audit and Appeals Representation,  Tax Preparer Penalty Mitigation, Payroll Tax Audits, and California Sales Tax Problems. He may be reached at 310-208-6200.