Code Sections 6694 and 7216. . . Treasury Circular 230 . . . Office of Professional Responsibility . . . AICPA Statements on Standards for Tax Services . . . every tax partner and senior manager faces a daunting array of new “guidance”. Rarely have tax and financial statement issues been so intertwined – and so likely to cause problems for tax practitioners. All CPAs must become familiar with risk analysis of tax return positions. This program explains what it takes to avoid penalties and keep fees reasonable.