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March 9, 2026

Willkie partners Shane Nix and Andrew Strelka and associate Samuel Hoops co-authored a two-part article in Daily Journal titled, “They Actually Put That in Writing? Common Mistakes in Written Tax Advice.” 

The article addresses some of the most common mistakes in written tax advice as well as the risks they pose for the practitioner as well as the client. Part I focuses on what constitutes written tax advice and the potential pitfalls of accepting unverified facts provided by a client or a third party. Part II highlights the importance of taking audit risk into account and the dangers associated with recycling prior work, including the misuse of artificial intelligence.

The Willkie team co-authored the article with Sharyn Fisk, the former Director of the IRS Office of Professional Responsibility and currently a professor at California State Polytechnic University-Pomona.

Shane Nix is a partner in the Tax Department and the Entertainment Transactions Practice.

Andrew Strelka is a partner in the Tax Department and Chair of the Tax Resolution Practice Group.

Samuel Hoops is an associate in the Tax Department and Entertainment Transactions Practice.

Read Part I of the article here; and Part II here (subscription may be required).

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