P and P, LLP. is a Denver based tax accounting firm that specializes in handling complex real estate tax matters. In early April, it was asked by a new client to provide a tax opinion in connection with a pending real estate transaction in which the client was seeking guidance regarding the application of certain original issue discount (OID) tax provisions. In early May, after reviewing the real estate purchase and sale agreements, including loan documents, the firm issued its opinion that "...based upon our analysis of the transaction and applicable tax authority, more likely than not, the OID rules would not apply..." Because the transaction had yet to close due to a delay in termite inspections, the opinion was signed and given to the client, but the date was not filled in. The lead partner in the firm told the client to fill in the opinion letter date when the deal closing occurred. In mid-June, Treasury announced changes to OID rules that applied prospectively to transactions closing after the issuance of the announcement. Although the termite inspections had been completed, due to other delays in acquiring financing, which were unknown to the partner, the actual closing of the real estate purchase did not occur until July. At the closing, the client appropriately dated the opinion letter in order to complete the closing and real estate transfer. Does the client have the right to rely upon the partner's opinion? What duty did the partner assume by handing over the unsigned letter and giving the client carte blanche to sign it? What should the partner have done in lieu of the approach taken?