What we learned is that, per the IRS's IRC Section 6694 -- "The More Likely Than Not" syndrome -- it is getting much more difficult to take aggressive positions on behalf of our clients. The IRS is turning tax professionals into "auditors" instead of advocates for our clients.
Michael A. Rozbruch, CPA, CTRS, Founder and CEO of Tax Resolution Services, Co.
CPA Magazine, January 2010