Forbes, Why Tax Opinions Are Valuable, by Robert W. Wood (Wood & Porter, San Francisco):
What taxpayers really want is to have their tax position upheld. That makes the best reason to get a tax opinion to help secure your position. An opinion—especially one prepared not at tax return time but while you are still effecting the purchase or transaction involved—can help put you in the best possible light on both the facts and the law.
See also What Good Is a Tax Opinion, Anyway? 128 Tax Notes 1071 (Sept. 6, 2010).
