Doc 2005-5011 (3 pgs)

(C) Tax Analysts 2005. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content. 2004.

A Detailed Guide to Tax Opinion Standards

By Anonymous

The following guide to tax opinion standards has been making the e-mail rounds lately. If you are the creator of this guide and would like to get public credit for your work, please send conclusive proof to us at taxnotes@tax.org. We have a hunch this orginated in Canada, which would not surprise us. Canadians are generally pretty funny.

Tax Opinion Standards

Percentage Chance of Success
100% 99% 98% 97% 96% 95% 94% 93% 92% 91% 90% 89% 88% 87% 86% 85% 84% 83% 82% 80% 79% 78% 77% 76% 75% 74% 73% 72% 71% 70% 69% 68% 67% 66% 65%

Standard of Opinion
Will Will at the Ivory Soap level Will almost certainly Will almost all the time I would be astounded if we lost I would be very surprised if we lost We will not lose this one It had better be right I would tell my mother-in-law to do this I would tell my mother to do this I would tell your mother to do this Like crossing the street Its in the bag They dont get much better You dont need an opinion Why are you asking the question? Its almost in the bag One could imagine a will Stronger than strong should Strong should Essentially, strong should Better view is a strong should Not without hesitation, strong should Better than good should Good should Odds are high Remarkably likely Very likely Better than weak should Weak should We expect to win In all probability In all likelihood Looking good Should probably

TAX NOTES, March 21, 2005

1469

Doc 2005-5011 (3 pgs)

COMMENTARY / TAX HUMOR

Percentage Change of Success

64% 63% 62% 61% 60% 59% 58% 57% 56% 55% 54% 53% 52% 51% 50% 49% 48% 47% 46% 45% 44% 43% 42% 41% 40% 39% 38% 37% 36% 35% 34% 33% 32% 31% 30% 29% 28% 27% 26% 25% 24% 23% 22% 21% 20% 19% 18% 17% 16% 15% 14% 13% 12% 11%

Standard of Opinion
Most likely Likely Favorable prospect Not without hesitation, should Not a bad prospect Reasonable prospect Fair prospect Well grounded hope There is reason to expect Better view Ought to be right Not without hesitation, the better view More likely than more likely than not More likely than not Your guess is as good as mine Less likely than not Less likely than less likely than not Almost there I hesitate to predict Depends on the day of the week If we get the right judge A very good shot A good shot It arguably could work It arguably might work God willing Depending on the facts There are good arguments Could be in the cards Stranger things have happened Throw of the dice As taxpayers counsel, I would not be ashamed to argue this in court Not without considerable doubt With some good fortune Might Might be argued that Stands a chance Might stand a chance It could be that it might work It might be that it could work Not very likely Conceivably Conceivably, but not hopeful Ive seen worse Perhaps arguable Within the bounds of possibility Maybe Maybe but not likely Not likely enough Possible but not likely Maybe Enron would do this As a CCRA lawyer, I would not be ashamed to argue this in court It should work, but it wont It could work, but it wont

(C) Tax Analysts 2005. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content. 2004.

1470

TAX NOTES, March 21, 2005

Doc 2005-5011 (3 pgs)

COMMENTARY / TAX HUMOR

Percentage Change of Success

10% 9% 8% 7% 6% 5% 4% 3% 2% 1% 0%

Standard of Opinion
It might work, but it wont Tell them you didnt know Perhaps if nobody finds it You have got to be joking Anything can happen, but this wont You must not understand the legislation Canadian jails arent bad I wouldnt wish it on my enemies Not bloody likely Not in a month of Sundays Not

(C) Tax Analysts 2005. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content. 2004.

TAX NOTES, March 21, 2005

1471