Thanks ATX Guru and others. Actually, I am a tax professional, tax attorney and CPA 28 years. I work at a Fortune 500 company...we use Corptax. This forum actually came up on a search and was just curious to get other thoughts. I do agree in general with your conclusions. It's actually black and white for attorneys who are practicing law per se and referring cases to other attorneys on a regular basis..that is actually very common and part of "their business". This fact pattern differs a bit from someone who has referred one case in his lifetime. Is that part of his "trade or business"? It would definitely be a tough argument but we have an IRS in office in our office and I have worked with/against them for 28 years and love a good fight. I have not got around to looking for cases at this point but might do that to see if I can find an once of grey. Give an a slight crack and I'm willing to fight.
