The flyer for the 40th Heckerling Institute on Estate Planning (the "Miami Institute" to the old-timers) just came in today. You can find more information here. I note with interest a brand new topic, one of the special sessions: The Gathering Storm—Circular 230: What Does It Mean and What Do We Do? Among the questions to be explored: "Should every item of paper and electronic mail generated by a law or accounting firm contain a statement that it cannot be used to avoid tax penalties?"
I submit that to reasonable men, the question answers itself. When disclaimers get plastered on everything, they soon mean nothing. However, it seems that to the regulators (and those who must follow their commands), there's no such thing as too much information.
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