Brainstorming to Identify and Manage Tax Risks— footnotes

¹ Treasury Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers Before the Internal Revenue Service.

² See Sec. 6707A, added by AJCA Section 811, and Sec. 6700, amended by AJCA Section 818. For details about reportable transactions and penalties, see Schaefer, Tax Practice Management, “Reportable Transactions—What Tax Advisers Need to Know,” TTA, September 2005.

³ See “Tax Risk Management, The Evolving Role of Tax Directors,” Ernst &Young (2004).

⁴ See Id.

⁵ Statement on Auditing Standards No. 99, Consideration of Fraud in a Financial Statement Audit (AICPA 2002).

⁶ Asare and Wright, “The Effectiveness of Alternative Risk Assessment and Program Planning Tools in a Fraud Setting,” 21 Contemporary Accounting Research 325–352 (2004).

⁷ Robbins, Essentials of Organizational Behavior (Prentice Hall 2000).

⁸ Id.

⁹ See GroupSystems software, available at www.groupsystems.com/page.php.