So I get an email recently from an attorney who, as far as I know is a general litigator, and doesn’t specialize in tax matters. This boilerplate addition, which apparently gets automatically added to all outbound emails, is a stroke of genius:
IRS Circular 230 Notice: To ensure compliance with requirements imposed by the IRS, please be informed that any federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
Oh yeah, now we’re doing some serious lawyering. Adding a rote IRS notice in every firm email you send out is not something that most lawyers would think of doing.
I’m going to set up an automated legal research alert so that I can get notified as soon as there is some litigation involving a lawyer who gets penalized for not putting in a rote tax circular notice in all of their outbound emails. And I’m making a note to myself to quit practicing law as soon as that happens.