Legal and disclosures

Circular 230 and Tax Advice Notice

Website content, diagnostics, checklists, calculators, readiness scores, articles, and informal communications are for general informational and educational purposes only. They are not written tax advice and may not be relied upon to avoid penalties or support any specific tax position.

Written advice and engagement scope

Any client-specific tax advice, tax return position, controversy response, opinion, or planning deliverable requires a written engagement scope, review of relevant facts and documents, and appropriate professional judgment.

No reliance on public content

Visitors should not rely on public website materials to take, avoid, amend, disclose, file, report, defend, settle, or implement any tax position. Consult qualified professionals before acting.

Facts and documentation matter

Tax conclusions depend on complete facts, current authority, procedural posture, taxpayer history, documents, elections, deadlines, and professional review. A public page or diagnostic cannot evaluate those elements for a specific taxpayer.

Representation and privilege

CPAs and enrolled agents may represent taxpayers before the IRS. Once a taxpayer authorizes a practitioner on Form 2848, Power of Attorney and Declaration of Representative, and that authorization is recorded in the IRS Centralized Authorization File (CAF), the practitioner may generally receive notices, discuss the matter with the IRS, and act within the scope described on the form. The scope of any authorization is defined by the taxpayer and does not by itself make communications privileged.

IRC Section 7525 provides a limited confidentiality privilege for communications with a federally authorized tax practitioner, a category that generally includes CPAs and enrolled agents. That privilege applies only in noncriminal tax matters before the IRS and noncriminal tax proceedings in federal court. It does not apply to criminal investigations or proceedings, generally does not apply in state or local tax matters, and does not extend to FBAR or other FinCEN reporting. Section 7525 is narrower than the attorney-client privilege and should not be assumed to cover a communication without professional review of the specific facts.

Matters that involve potential criminal exposure, questions of willfulness, privilege, or representation in the United States Tax Court generally call for a licensed attorney. Where a CPA’s or enrolled agent’s analysis is needed in such a matter, that work may be structured through the attorney’s engagement, commonly a Kovel arrangement, so that the practitioner’s involvement can be covered by the client’s attorney-client privilege. MMVFO is not a law firm and does not provide legal representation; where these issues are present, MMVFO coordinates with the client’s attorney under appropriate written terms.

Advisor and affiliate coordination

Where attorney, investment, insurance, financial planning, securities, or other regulated services are required, those services are provided only by properly licensed or registered professionals under appropriate written terms.