Written Advice and Tax Positions
Learn the decision pattern the exam can test, then apply it to a realistic taxpayer fact pattern.
What changes the answer?
A disclaimer cannot repair analysis built on implausible assumptions or ignored facts.
A tax-practice scenario
A promoter gives the EA a favorable template opinion for a client's transaction. Independently test facts, authority, purpose, and promoter claims.
Identify the taxpayer, entity, transaction, and tax period first. Write the controlling tests in order, apply only the relevant facts, and keep the reporting result separate from any planning recommendation.
Do not take this shortcut.
Treating a third-party memo or client representation as automatically reliable.
Turn the rule into recall.
Use an advice file with facts, assumptions, missing information, authorities, analysis, conclusion, and reliance limits.
- ExplainState the governing distinction without notes.
- ApplyChange one fact in the scenario and predict the new result.
- RetrieveAnswer an unseen question, then review every option.
Official source and scope
This lesson follows the current PSI content outline and uses the IRS reference below for the underlying tax or practice framework. Always confirm current forms, instructions, thresholds, and effective dates before advising a taxpayer.