The ABA Committee on Government Affairs on Friday sent this letter to the IRS expressing its opposition to the proposals to require taxpayers to disclose uncertain tax positions to the IRS:

On behalf of the ABA, I write to express our concerns regarding the proposals contained in IRS Announcement 2010-9, 2010-7 I.R.B. 408, Announcement 2010-17, 2010-13 I.R.B. 515, and Announcement 2010-30, 2010-19 I.R.B. 668 (collectively, the Announcements). The Announcements would require disclosure of uncertain tax positions through the required filing of Schedule UTP by certain business taxpayers. ..

We are concerned that the disclosure proposals set forth in the Announcements, brequiring identification of specific uncertain tax positions and elaboration of the taxpayer’s views and assessments of those positions, will undermine the protections afforded by the attorney-client privilege and attorney work product doctrine, as well as the related § 7525 tax practitioner’s privilege. …

[T]he ABA urges the Service to withdraw the disclosure proposals in the Announcements and instead rely on existing methods of obtaining information.

On the other hand, Carl Levin, Chair of the Senate Permanent Subcommittee on Investigations, sent this letter to the IRS praising its approach in the three announcements and urging that "the proposal be strentghened to cover more taxpayers."

Update:  Comment letter from Miller & Chevalier (Washington, D.C.).