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Tax-Unsophisticated Client

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Letter to Sue (Tax-Unsophisticated Client)

Dear Ms. Ross:

Thank you for the opportunity to work with you on this tax planning matter. Before I render any advice regarding this set of facts, it is important to lay out pertinent information about the opinion I will be providing.

Responsibilities

It is my role as a tax professional to help provide guidance where the tax law is unclear, or there is uncertainty between the different taxing authorities. My responsibility is to provide a position on the matter that has a realistic possibility of being sustained if questioned; this means exercising a good faith belief that the position has at least a 1 in 3 chance of being upheld if challenged by the Internal Revenue Service (IRS).

In other words, …show more content…
One of these factors include that the bonus payment must be considered “reasonable”. What constitutes as “reasonableness” is determined on a case to case basis. When determining what is considered “reasonable”, a few important factors to take into consideration include: the employee receiving the bonus’s qualifications, the extent of the employees work, whether a close relationship exists with the employee, the rates of compensation for comparable positions, and the amount of compensation paid to the employee in previous …show more content…
Costanza:

Thank you for the opportunity to work with you on this tax planning matter. Before I render any advice regarding this set of facts, it is important to lay out pertinent information about the opinion I will be providing.

It is my role as a tax professional to help provide guidance where the tax law is unclear, or there is uncertainty between the different taxing authorities. My responsibility is to provide a position on the matter that has a realistic possibility of being sustained if questioned; this means exercising a good faith belief that the position has at least a 1 in 3 chance of being upheld if challenged by the Internal Revenue Service (IRS).

In other words, my opinion does not bind to the IRS, and I cannot guarantee what the outcome will be if this position is challenged. This means Ms. Ross will remain responsible if any tax liabilities arise from an unfavorable IRS or judicial decision on this matter.

Based on our research, C Corporation will be able to deduct the bonus payments made to all employees other than Sue in the current year, as long as the payments are made before March 15th of the following year, and as long as they are considered “reasonable”. My conclusions are summarized by the following authorities as of October, 17,

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