Class, it may be hard for the IRS to prove fraudulent intent. But the IRS released Circular 230, which covers written advice provided by tax advisers. A common form of disclaimer used by tax practitioners is as follows:

IRS CIRCULAR 230 DISCLOSURE Pursuant to requirements imposed by the Internal Revenue Service, any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of avoiding penalties imposed under the United States Internal Revenue Code or promoting, marketing or recommending to another person any tax-related matter. Please contact us if you wish to have formal written advice on this matter.

Do you think this may help the IRS when in the past taxpayers had more credibility in claiming they relied on the paid experts?