We will provide clients with the highest quality of representation concerning Federal tax issues by adhering to best practices in providing advice and in preparing or assisting in the preparation of a submission to the Internal Revenue Service. In addition to compliance with the standards of practice provided elsewhere in this part, best practices include the following:
1) Communicating clearly with the client regarding the terms of the engagement.
2) Establishing the facts, determining which facts are relevant, evaluating the reasonableness of any assumptions or representations, relating the applicable law (including potentially applicable judicial doctrines) to the relevant facts, and arriving at a conclusion supported by the law and the facts.
3) Advising the client regarding the import of the conclusions reached, including whether a taxpayer may avoid accuracy-related penalties under the Internal Revenue Code.
4) Acting fairly and with integrity in practice before the Internal Revenue Service.