Legal opinion letters from tax attorneys
A formal, signed legal opinion that documents the facts, the law, and our conclusion at a stated confidence level, so that you, your accountant, or the IRS can rely on it. For tax positions the IRS has not addressed, and for crypto losses under Section 165.
Opinion letters services
Two kinds of letters, for two kinds of questions.
What an opinion does, and what it does not.
An opinion is not a promise of the outcome. It is evidence that the position was analyzed by a qualified professional before you acted, which is what reasonable cause and good faith require to avoid the 20 percent accuracy penalty, and what exchanges and investors want to see before they rely on a token.
The confidence level is a legal conclusion: will, should, more likely than not, or substantial authority. A reasoned analysis has to support it, and ours do. Letters are written by attorneys with the firm’s CPAs on the numbers.
Results depend on the facts of each matter and are not a prediction of the outcome in your case.
Crypto scam victim? The IRS now lets you deduct the loss.
Who handles opinion letters matters
Opinion letters are written by the firm’s attorneys and signed at a stated confidence level.
Questions people ask before they call
Straight answers to the questions that come up first. The consultation is where we answer the rest.
No. An opinion letter states the attorney’s analysis and level of confidence. It does not bind the IRS or a regulator. What it does is document reasonable reliance on qualified advice, which matters if a position is later questioned.
The client and anyone the engagement letter names as a permitted recipient, such as your tax preparer or an investor. We address that in scoping so the letter is written for its real audience.
Yes. Return preparation is handled by our tax team at Gordon Law and by Gordon Tax, our affiliated accounting firm. When a theft loss or a tax position needs to be reflected on a return, the teams coordinate directly.
Schedule a confidential consultation
Tell us what is going on. A member of our client success team follows up, explains how we work, and matches you with the attorney whose background fits your matter.
