¹ For a discussion of Schedule M-3, see McGowan and Killion, “Schedule M-3: Closing the Corporate Book-Tax Gap,” 36 The Tax Adviser 408 (July 2005).

² See, e.g., Jade Trading, LLC, Fed. Cl., 4/22/05.

³ Treasury Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents and Appraisers Before the Internal Revenue Service.

⁴ For a discussion, see Chassman and Brennan, Tax Practice & Procedures, “AJCA Penalties for Noncompliance with Reportable Transaction Regs.,” 36 The Tax Adviser 232 (April 2005).