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Considers the ethical issues faced by advisors in structuring tax motivated transactions, resolving tax controversies with the Internal Revenue Service, and representing tax fraud defendants. These issues will be studied in the context of the relevant professional rules of legal ethics, administrative rules governing practice before the Internal Revenue Service, and statutory penalties applicable to taxpayers lacking adequate support for their positions. Particular emphasis will be given to the interplay of these rules with the process and relevance of issuing a professional opinion. This course meets the Legal Ethics graduation requirement for the JD program. Pre-requisite: Not open to second year JD students who are not enrolled in the Joint Degree Program without the permission of the instructor. Basic Federal Income Tax is a pre-requisite for JD candidates. Method of Evaluation: Examination Method of Instruction: Problem Method