The Atlanta Lawyer January/February 2013 | Page 28
section update
Tax Law Section Update
By Julian A. Fortuna
The Saylor Law Firm LLP
O
n Tuesday, January 22, 2013, the Tax Law Section
of the Atlanta Bar Association and the Taxation
Section of the State Bar of Georgia held a joint CLE
program on Ethics and Professionalism in the practice of
tax law. David F. Golden, a partner at Troutman Sanders
presented the ethics portion of the program. David covered
recent changes to Treasury Department Circular 230
which sets forth regulations governing practice before the
Internal Revenue Service ("IRS"). Practitioners who violate
these regulations may be sanctioned by public reprimand,
suspension, disbarment and/or monetary penalty. In most
cases, practitioners are sanctioned for failing to file or pay
taxes for which they are personally responsible. Historically,
these regulations have applied only to attorneys, CPAs and
other specified professionals who give written advice to
taxpayers or represent them before the IRS. In May 2011,
the IRS expanded the regulations to cover individuals who
prepare tax returns for others, requiring them to pass a
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January/February 2013
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qualifying exam, pay an annual application fee and take
annual CLE. However, on January 18, 2013, in Loving v.
IRS, Civil Action No. 12-385, the United States District Court
for the District of Columbia invalidated that portion of the
regulations and enjoined the IRS from enforcing them. David
noted that the IRS Office of Professional Responsibility is
reeling from this decision and has suspended enforcement
of its regulation of tax return preparers pending its probable
appeal of the case. Much less controversial changes to other
portions of the Circular 230 regulations were proposed on
September 17, 2012, and are likely to be finalized this year.
These changes include a new "competency requirement"
which states that a tax practitioner must exh