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Stephen Whitlock, deputy director of the OPR, and Kayla Gillan of the PCAOB, along with CalCPA members Kip Dellinger, a senior tax partner and director of the Estate & Gift Tax practice of Kallman and Co. 29) The phrase "potentially applicable judicial doctrines" is troubling for practitioners, because what is potentially applicable may not be as clear when a practitioner is preparing an opinion, as compared to when the opinion comes under OPR scrutiny. It would be helpful if Treasury and OPR provided examples of situations where this exception to the principal purpose rules applies. |
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