I wrote the “Levels of Assurance in Tax Opinions ” many years ago, with some help from my friends. At the time I was debating what the correct way of expressing the level of assurance in a tax opinion. I was a proponent of will, should and more likely than not. My colleague was thinking that the better view was sufficient. I tried to illustrate the full range of possible opinions that could be given in this work. It surfaces around the tax community now and again and I thought I should post it here and allow official downloads of the original. You can spot derivations by the missing 81% threshold. I may open this page up to comments soon and take submissions for that spot.
GAARMAGEDDON™