Wesley is an absolutely amazing tax planner. He is a member of the AICPA and is widely recognized for his expertise in assisting numerous clients who invest in tax shelters and in recommending associated tax return positions. Wesley rarely worries about the possibility of audit and counsels his clients to take the view that "whatever will be, will be." But he never suggests that clients play "audit roulette," and he always makes clear to his clients that there are risks involved in tax shelter investing, such as losing all of your money.
Further, he makes clear in his client engagement letters that there's always a possibility of audit and he does not guaranty any particular tax result as a consequence of advice given as to recommended tax return positions. However, he never spells out the details involved in the inherent risks, preferring to keep his clients ignorant of such risks. In his own defense, Wesley comforts himself in the knowledge that he will assuredly not allow his clients to become involved in tax shelter arrangements where deductions taken do not meet the realistic possibility of success standard of being sustained on audit. In this way, he feels comfortable that his clients are protected despite the fact that they have not had all of the tax and other risks explained to them. As an AICPA member recommending tax return positions, is Wesley correct in his approach? Discuss.