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Practitioner who having been retained by a client with respect to a matter administered by the irs discovers that the client has not complied with the united states tax laws the practitioner must

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the practitioner must advise the client of the consequences as provided under the Code and regulations of such noncompliance, error, or omission.
Failure to advice this will expose the practitioner to potential lawsuit equals to the potential loss experienced by the client from the  noncompliance, error, or omission

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