Unlocking Collaboration and Trust in the Tax Law Community with Nancy Prosser

Hosts & Guests

Meredith Smith, State and Local Tax Senior Manager

Tram Le,  State and Local Tax Senior Manager

Nancy Prosser, General Counsel at the Multistate Tax Commission

What You Will Discover:

In this episode of the SALTovation podcast, we speak with Nancy Prosser, General Counsel at the Multistate Tax Commission. Nancy shares her experiences navigating through the complexities of introducing major legislative tax changes and discusses the intricacies of rule-making and policy development. She also talks about the importance of collaboration and transparency within the tax community, be it through engaging with different states’ revenue departments or fostering constructive dialogues within the MTC.

Listen this week as we take a look at the evolution of tax legislation and policy from the trenches of legal administration to the broader scope of multi-state coordination. 

Topics Discussed in this Episode:

  • Nancy Prosser’s unconventional journey into state and local tax 
  • The implementation of Texas’ franchise tax reform: heavy emphasis on rule development, training, and taxpayer education to ensure a smooth transition
  • The Multistate Tax Commission plays a pivotal role in addressing interstate tax policy issues and fostering a collaborative approach amongst state tax administrations.
  • The symbiotic relationship between tax professionals across sectors and the mutual growth derived from sharing expertise.


        • “We brought the multistate tax commission in to do training to help taxpayers and practitioners understand how the comptroller’s office was going to administer this very major shift.” -Nancy Prosser [08:38]


        • “As I advanced through the agency and had more of a kind of global perspective on the agency itself in our work, it dawned on me more and more that decisions that were made in terms of tax policy did not just affect Texas, obviously, but did impact the world because so many people were doing business in Texas.” -Nancy Prosser [20:43]

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    [00:00:00] Meredith: Welcome to SALTovation. Hi, Nancy. Thank you so much for joining us today. It's a pleasure having you and getting the opportunity to speak with you where we talk about the issues and strategies to help you make sense of

    [00:00:13] state and local tax.

    [00:00:17] Love that. And so, can you share your journey into state and local tax and the career path that led you to the MTC?

    [00:00:26] Nancy: Sure. So, when I was entering law school, I had just finished a, uh, Master's in Business Administration. So, I had taken some tax courses as part of that. Uh, my undergraduate degree is in psychology, but I also had taken some business classes and I was aware of taxes just because my dad was a CPA in a small midwestern town and was used to not seeing him for weeks and months on end during tax season when he was in school.

    [00:00:53] doing returns for his clients. But admittedly, when I entered law school, I did not know anything about state and local tax. Uh, I took federal income tax. I took at least one other tax class, but I don't recall, uh, the University of Texas at that time having, uh, any SALT classes. So, uh, that was not on my radar.

    [00:01:16] But I started clerking, uh, at the Texas Attorney General's office in what's called the Taxation Division. And those are the attorneys who represent the state controller, which is the Texas agency, uh, charged with administering state taxes. And so they would do the, the litigation and appellate work, uh, when there were disputes over the meaning of a statute or its constitutionality and, and whether or not the controller had proper interpretation, uh, and legal interpretation of, of these laws.

    [00:01:48] So, uh, I moved into an attorney position after I got my bar results and spent roughly the next six years working there, uh, doing mainly sales and use tax cases, uh, some franchise tax cases, franchise tax being the main business tax in Texas now referred to commonly as the margins tax. Um, I was, I was, You know, reminiscing about my career, getting ready to do this and, uh, recalling that the, the, the 1 group of cases that I inherited when I moved into an attorney role, uh, where the controlled substances taxes, uh, the drug tax that existed at that time.

    [00:02:26] And, uh, the 1st appellate argument I ever did 6 months after getting my, my bar license and starting to do tax cases was a, a court of appeals. It's a case concerning the, the Texas drug tax at that time. So um, but it was a, a great, uh, six plus years. I had some wonderful mentors, you know, people who really knew Texas tax, uh, were just superb trial attorneys and appellate specialists.

    [00:02:53] One of the things about the attorney general's office at that time in my early part of my career was, uh, The attorneys who handled the case at trial typically would get to handle the tri, the case at the appellate level as well. There was not a solicitor's general's office like there is today. So from a very young, uh, age of being a, a attorney, uh, I had a lot of autonomy in the cases that I handled a lot responsibility to, to work them up, you know, work with the people in the controller's office to understand the issues, uh, and then, you know, handle them at trial and at and at the pal appellate level.

    [00:03:29] And, uh, you know, typically with these tax cases, uh, You know, they're, they're business related, uh, cases, and if they're in court, it's because they're questions of first impression. If they've been answered, there's no reason for them to be litigated, and, and I realize in hindsight, I didn't really appreciate, uh, how these cases were questions of first impression that might impact the jurisprudence of the state of Texas, um, and, and of course it's not just that individual.

    [00:04:02] Taxpayer, uh, but many taxpayers as well. And, and, uh, just the dollars involved, uh, could be much greater than the specific amount in controversy. So, uh, it really, it was a great. experience and a great, um, opening to being a salt attorney. Um, like I said, I was there for a little over six years and then I left for a short period of time.

    [00:04:29] Uh, my husband's work presented us with an opportunity to live in Europe. So I, I had a interesting moment where it was kind of this question. I could stay. In Texas, uh, at the Attorney General's office litigating, you know, tax cases with it in or my husband and I and the dog and the cat could go to Europe.

    [00:04:48] And so I made the decision to go to Europe for a while, but then came back and joined a large law firm doing state local tax, you know, representing people before the Texas controller's office. So I got. The flip side of the, uh, experience, not so much litigation, but just, uh, you know, having to work with the controller's office and any other people that I had relationships with.

    [00:05:14] Uh, that I had developed during the years I was in the control or in the, the, uh, attorney general's office. Uh, those continued or others developed while I was, uh, with the law firm and, and handling matters before the controller's office. So about 10 years in, I left the law firm and then had an opportunity to go into the controller's office, and that just seemed like a good fit at the time.

    [00:05:38] When I kind of took stock of what I had done so far in terms of salt work, you know, representing clients, you know, representing the controller's office. But what I realized 1 of the things I really enjoyed was the, the aspect of policy and, and rather than defending it, I had an opportunity to actually help.

    [00:05:57] Make it and impact the salt world from that perspective, and that was very attractive. So I went into the controller's office and in 2004, as basically a frontline policy analyst and, uh, just, uh, continued there for almost 16 years and had just a lot of really great opportunities. Um, some that I asked for others that I was asked to to, uh.

    [00:06:25] To take roles to step into along the way, but just just a gradual progression of learning more in terms of tax policy, tax administration, legislation, continuing to do support for litigation. The attorneys, whether they were in the administrative hearing section or at the attorney general's office to support litigation on that front.

    [00:06:51] But, uh, just a really great opportunity to to. to see a bigger picture of, uh, state and local tax, um, along the way. So, uh, so that's a little bit about how I've gotten to where I am today at the, uh, the MTC.

    [00:07:06] Meredith: Yeah. So, excuse me. So you would have been at the comptroller's office when the margins tax went into, kind of was enacted and there was that shift.

    [00:07:17] What was that? What was that like? Or how was, how were those conversations?

    [00:07:22] Nancy: So, so again, you're absolutely right. So again, I joined the comptroller's office in 2004 and, uh, by the time, uh, July of like 2006, I had moved into the role of, uh, tax policy area manager. And so that was the group of attorneys and others who developed rules, uh, were the main rule writers in the policy area.

    [00:07:49] And you're absolutely right. The, the, the. I still call it the franchise tax, but I know a lot of people call it the margins tax. I do too. Um, I'm sorry. It's just still like fingernails on a chalkboard for me, when people say the margins tax, I'm like, there's no such thing as the margins tax, the franchise tax.

    [00:08:05] But anyway, when, when the franchise tax, you know, uh, changed on it to the margin calculation. Yeah, I was managing that group of, you know, all the policy folks, including the franchise tax group. And one of the key things I remember from that time was how critical it was to develop the rules to get things out and in a timely manner so that people knew how to comply with this brand new calculation.

    [00:08:38] There was a team at that time of, you know, 4 or 5, uh, franchise tax experts, um, thank goodness, people that had been there for a while and, uh, along with, uh, William Hamner, who's, you know, still involved at the work at the commission. But it really, you know, I was not directly involved, but again, I was managing that, that team.

    [00:08:59] And, uh, they just, they were, You know, really rose to the occasion as I think back to that time, uh, not only working on the rules and, and, and all the other internal aspects of tax administration that had to get, uh, developed in terms of the systems and, uh, you know, forms and that kind of thing. But also.

    [00:09:18] All of the different trainings that were done, uh, I remember that, that team of, of analysts, Janet Spees and, uh, uh, Teresa Bostic and, you know, some of those folks, uh, that, you know, went all over the state doing seminars and trainings to help. Taxpayers and practitioners understand how the controller's office was going to administer this very major shift in one of the major taxes.

    [00:09:48] So, uh, it was, uh, an interesting place to be at the time. And of course, it's been interesting to see how. Those issues have gotten litigated over the years, uh, as far as, you know, how, how the controllers interpretation of the statutory language has has developed over time and the changes that the legislature has continued to make to tinker with that part of Texas law.

    [00:10:15] But, um, yeah, interesting that you asked me that question, because, uh, it does bring back memories of again, as I think about it. Just what a terrific team effort it was internally, uh, but also like so much of what is good about good tax administration, really bringing in the, um, the perspectives of all the stakeholders to make sure you're listening to, you know, what other people are thinking about and whenever possible to try and get on the same page as far as, you know, what, what the policy is going to be, why, and, and how everybody can move forward together.

    [00:10:53] Meredith: Yeah, because I really remember, I mean, I was a student. Senior, I think in big four, reading the rules, trying to be like, okay, well, we have this giant taxpayer first off, you know, here are our new unitary rules, right? And the ownership and what does our group look like? And then going into, okay, well, what is our revenue structure?

    [00:11:14] And then again, reading the rules and the direct references to the federal return. And so I feel like that. You know, was one of kind of the biggest pieces of legislative change that I learned as a little baby senior because it was a whole shift where everyone was learning from scratch because no one knew what they were doing, right?

    [00:11:38] So it was kind of a cool kind of from a practitioner standpoint point of teaming as well because you're like, okay, well, here's how we read the rules. Here's how it's going to apply. What does this mean? And so I specifically remember that Um, and like putting together our work papers of how we're going to calculate it and get it onto the return.

    [00:11:57] And I'm still using those work papers 15 years later, right? So it's just, yeah, just hearing that teaming effort from the comptroller side and seeing because that's the exact same thing that we did on the practitioner side.

    [00:12:11] Nancy: Like you said, everybody was scrambling to figure out how this was going to work.

    [00:12:15] And as you mentioned, you know, combined reporting came on the scene that you think about in other states, how. You know, that's still, you know, out there for some states yet to perhaps go to combine reporting, but, you know, some states that have done it, it's taken multiple times and tries at the legislative level and here kind of out of the blue.

    [00:12:35] It just got stuck in there and nobody in, inside the agency, you know, had much exposure to it. And that's one thing I remember, we brought the Multi State Tax Commission in to do training for the auditors and policy folks to, to understand how to think about, you know, auditing and thinking about, you know, You know, combine returns and unitary and, and I still marvel that, you know, in all these years, Texas has had no cases on that issue.

    [00:13:05] Somehow, um, we seem to have navigated, uh, through those, those unitary issues in a way that I guess, you know, between the rules and policy and, and how things have been audited. Uh, we haven't had any, any litigation disputes on that after all these years.

    [00:13:22] Meredith: Yeah. Well, so then I will say, you know, what then motivated you to go from the comptroller's office to the MTC?

    [00:13:30] So

    [00:13:32] Nancy: again, going back to when I became tax policy area manager, uh, in the, in the agency in 2006, um, The person whose position I took, I, I answered to her, uh, before I moved into that role. And I knew there were these meetings she would go to every once in a while, every few months. And she'd be on certain phone calls every once in a while, uh, talking about these tax issues, not realizing that, that That was the Multi State Tax Commission that she was going and attending, and when I moved into her role, um, I was told, okay, you now need to attend meetings of the Multi State Tax Commission, and I didn't really understand, nobody really sat me down and told me much about what it was and how it worked, but they said you needed to go, so I said, okay, and so my, my first MTC meetings, I remember this, were in the summer of 2006 in Topeka, Kansas, and off I went.

    [00:14:27] I didn't know a soul. I had never, and they, they, I was told go to the uniformity committee meetings and go to the executive committee meetings. And so I, you know, walk into this room of people at this uniformity committee and, you know, just trying to get my bearings about which end is up. Um, I, I went to the executive committee meeting and I, I just sat like at the back of the room, just thinking I needed to just sit and observe and, and kind of.

    [00:14:54] Monitor what was going on and report and then somebody came and got me. They said, no, no, no, Nancy, you need to sit at the table. And there's like, this little table tent there for Texas. And I was like, you're Texas. You're Texas. I was like, I am.

    [00:15:08] Meredith: Yeah. And

    [00:15:09] Nancy: and, and after going to a couple of of these in person meetings, I finally was started again, figuring this out.

    [00:15:15] And then 1 day, it, it, it finally pinged in my brain that these other people sitting around this. Uh, at the executive committee meeting, like, were the heads of their departments of revenue. They were like, the Texas, you know, controller of public accounts. And, and here I was truly a low level policy manager in the agency.

    [00:15:37] But, as I have said, uh, many times now, that, uh, door that opened with the MTC, uh, was such a wonderful part of my career with the controller's office because of the people that I got to meet across the country and other departments of revenue. The issues that I was exposed to about multi state, you know, income, sales and use tax issues, but also, yeah, that wonderful opportunity to sit there representing Texas, uh, at the executive committee and, and, and having the opportunity to, to just have as role models, some of these really wonderful tax administrators, not that I didn't have good role models at the controller's office, but it was just, you know, another group of people who were, Very devoted to this area of, of law and, and, and really trying hard to, to get it right and, and do things well.

    [00:16:33] And so, uh, yeah, again, my, my career at the controller's office was very fortunate. And when I again entered as a frontline policy analyst, I had no, no aspirations to, to, to. To move into any particular role in the agency and let alone to, to move eventually into the role of general counsel, which is the last position that I, I held, but, but in that role, I was moving further and further away from doing state and local tax work.

    [00:17:08] And, you know, at that point, there really wasn't. Anyplace else for me to go with the agency, but I was at an MTC meeting in the fall of 2019 where they announced that then General Counsel Helen Hecht was going to be moving into this new role of Uniformity Counsel, so they would be, uh, going to, you know, look for a new General Counsel.

    [00:17:31] And I remember hearing that and this voice in my head just said, Nancy, That might be your next job. And so I just decided, you know, I, I, I've loved being a solid attorney. I've missed doing as much tax work as, as I had done before. Uh, I knew the MTC, I knew what it was about, and I just saw it as a, a great opportunity go to another level in my career as far as a more multi state national exposure.

    [00:18:02] And so I just decided I needed to throw my hat in the ring and apply. I wouldn't, I would never, you know, forgive myself if I didn't just try. And so, uh, I was very, uh, gratified to have gone through that process and been asked to become general counsel. And so, you know, now I'm one of. I've worked with a number of aid attorneys on our legal team.

    [00:18:24] And, uh, it's just, it's, it's, it's been the positive experience. I'd hoped for to really continue to grow in my knowledge and experience as a salt attorney. But at this level, where I'm at this. Fairly small organization, but boy, do we have a big imprint and footprint across the country. And it's just again, very gratifying just like it was when I was at the controller's office to have those those opportunities to to identify what is what is best about state tax administration and really try and bring that to the floor whenever possible.

    [00:19:02] So that, as I like to say, You know, at its best, we're going to increase certainty and clarity, and we're going to decrease risk and disputes, and try and find that common ground with, with all stakeholders having that opportunity to, to weigh in through the process.

    [00:19:19] Meredith: Yeah, and I want to. Spend some time talking about the MTC, but as you were talking and kind of thinking about what it's like to walk into a room of kind of, right, potentially the heads of the Department of Revenue, but as Texas, right?

    [00:19:33] It's kind of a silly question, but did any of kind of your cohorts when you would go to those MTC meetings ever give you all a hard time about like, come on, Texas. Why'd you do that? Now we have to, did you ever, did you have to ever have to take one for the state of Texas? If any one state, you don't have to call them out by name.

    [00:19:53] Nancy: No. Um, give you a hard

    [00:19:54] Meredith: time. You know, I,

    [00:19:56] Nancy: I, I don't remember any, any time and I, and I think, uh, but though I must say, I did become mindful, uh, as I learned more about the commission and just again, working on a multi state level that, that. Texas had a pretty big footprint, uh, across the country and, you know, and that's 1 of those things just even now, I find myself saying for a state and local tax attorney, you know, when you work in a.

    [00:20:24] Department of revenue. In a state like Texas, which at the time we would say, you know, it was like my later part of my career there, you know, Texas was like, had the 11th largest economy on the planet. Then it was the 10th. I looked it up recently for another purpose. Now they're saying, you know, it's the 9th largest economy on the planet.

    [00:20:43] So. As I advanced through the agency and had more of a kind of global perspective on the agency itself in our work, it really dawned on me more and more that decisions that were made in terms of tax policy did not just It didn't affect Texas, obviously, but really did impact the world because so many people were doing business in Texas.

    [00:21:05] And, but, but to your point, you know, as far as with, with other states, uh, I, I did try and stay, you know, humble. I mean, you know, we, we had an impact, but it, it did not at all diminish the, the, the impact. The camaraderie with my other, uh, you know, folks from the other departments of revenue and the other thing that I remember from that, that was really wonderful was, you know, there were times when when Texas in terms of tax policy would actually be aligned with.

    [00:21:37] With other states that you might not necessarily think politically, and in particular, I think about, um, back in the, you know, 2010, 13 area, where it at the federal level, the Marketplace Fairness Act was being looked at as a possible way for the states to get that remote seller access, uh, or access to, you know, having remote sellers collect and remit without a physical, uh, Presence in a state and and that federal bill, which, of course, did not ultimately pass, but it was kind of setting up this this dichotomy between the streamline states and the non streamline states, which, of course, Texas is a non streamline state.

    [00:22:24] And so it was this interesting. connection between Texas and other big states like California, New York, Illinois, and Florida, which again, politically, we're on different, different, yeah, today, but, but back then, as a matter of policy, though, as tax administrators, we had a common interest on behalf of our states that we wanted to make sure if there was going to be federal legislation, that, you know, we, we, We would be able to withstand whatever Congress was going to send our way.

    [00:22:58] And so it was just interesting to, um, to work on that issue, for example, and and work with other states on a tax policy basis that you might not think otherwise. So, you know, and to me, that's always been 1 of the great things about. Working in tax administration, even now, we don't look at ourselves as red state tax administrators, blue state tax administrators.

    [00:23:20] We're just all tax administrators. So we're just trying to get it right and and do the best we can. So, so that, you know, your question brings to mind that kind of memory as well.

    [00:23:31] Tram: So, so Nancy, um, I think you and I had met. at a ABA meeting, I don't know, sometime last year or so, and I do remember that conversation that you had asked me about, like, hey, if you have anything that, any taxpayer concerns, I'd love to hear it.

    [00:23:48] I, I'm, that was very, that made a big impression on me, just because I was like, I love hearing government say, we want to hear. You know, all the things that taxpayers struggle with or have issue with. And so, I mean, I'm from Texas, I don't know if you remember, but, um, so I'm in the big state of Texas and, I mean, the whole process where the rulemaking and, you know, making it public and, you know, the commentary period, I, I don't, I mean, I think other states have kind of similar process, but I feel like in Texas, we do a great job and me touting Texas, but, I mean, truly, um, you know, that, that, That process of getting all perspectives before a decision is made is so important.

    [00:24:29] Um, so I, I guess I felt like when we had that initial conversation, I, I had that same feeling. So I just kind of wanted to echo that. Well, for sharing that.

    [00:24:38] Nancy: Because it, it really is true. And I, I mean, I really do carry that, uh, and, and that's a hallmark, I think, of, of the agency. You know, as you say about with like rulemaking and, and I worked on many, many rules during the time I was with the Comptroller's Office and, uh, in fact, it's, it was actually one of the favorite parts of my job.

    [00:24:55] I really loved rule writing, which, you know, you would think that. I mean, that's like the ultimate tax nerd kind of thing to say, but, but it was always very gratifying. But, but, you know, that was one of the things that we did and, and I, I hope other state departments of revenue may, may do this in some way, shape or form, but, you know, had a very robust taxpayer advisory group and business advisory group, uh, and with the before we ever set rules to the secretary of state's office for formal.

    [00:25:27] noticing and the formal, you know, required legal 30 day comment period. We always sent those to the taxpayer advisory group and business advisory group to ask for their input. And, and I, that was always very welcome. I mean, it was a great way to collaborate, uh, make sure that, that we weren't missing something.

    [00:25:47] There was lots of times the taxpayer community would suggest language that would make it better. Um, and we were happy to have that. And so, uh, yeah, I think, I think that, you know, Texas does still does a great job with that, but, but it, but it's also a fun part and a meaningful part of being, uh, with the multistate tax commission that that as a governmental entity, which I know that's always a strange.

    [00:26:12] Thing to people that the MTC is government, but we do have that very robust public participation policy and that same commitment to a transparent process. Whenever we're working on uniformity projects, model rules, what have you. It's just and even if we can't agree that, you know, there's a. that, that this is a, the right way to do it, or, you know, there's differences of opinions, uh, or just disagreement that the MTC should even be doing something.

    [00:26:42] You know, we know that exists as well from time to time. Uh, it's still, you know, very much welcome to know that and, and to hear those voices and, and make sure, again, we, we get it as right as we possibly can.

    [00:26:55] Meredith: Well, I think that's something wonderful about the kind of state and local tax. community, right, is there are so many nuances, so many kind of different taxes that that one state can be responsible for administering so that, you know, it's an, it's impossible to be an expert in all 50 states on all of the possible tax types.

    [00:27:19] So by default, If you want to be good at your job or care about your job as a state and local tax practitioner, you know, interested party, you, you have to operate in the spirit of collaboration because it's impossible to know it all and do it all. Right. And so that's something that we always kind of, when we talk about as a team, just how, you know, just something that really resonates with our team is just always that spirit of collaboration and partnering and just getting to know who else is out there, what everyone else is suffering with, because also just a lot of things happen behind closed doors that you're not privy to.

    [00:27:57] And so it's nice to be able to have a community to share with and be a part of.

    [00:28:03] Nancy: And that, and that's one of those things as I get the opportunity to talk to young attorneys and such, which is one of the things I love to do now that I'm, you know, kind of the old guard, the old lady in the, in the, in the salt world after 30 years.

    [00:28:16] Uh, that's one thing I always tell them that whether it's been in the Texas community that I was part of, or now even at the national level, that is one thing about. Tax attorneys in general and, and, and that I have found it's just a wonderful group of people and you're absolutely right about, you know, at the salt level, uh, when, like I said, you know, you go to the meetings, there's just this great sense that.

    [00:28:43] I will be better if I share my knowledge with you and, you know, and it's not going to hurt me in terms of, you know, if I'm, you know, at some level, everybody's a competitor, you know, the private secretary, everybody's wanting clients, but, but at the same time, everybody benefits from people being fully informed and being able to give accurate information and share those experiences and all try and get better together.

    [00:29:09] Um, so, uh, yeah, that's that is definitely 1 of the things that I've I've experienced in my career as well. And and just the reality that. You know, there are people that will work in the public sector as well as the private sector at some points in their career, which I always want to make sure I make a plug out there for whoever might be listening to this.

    [00:29:29] If they're law students or people earlier in their career, I just want to say what a great, uh, group. Uh, experience, obviously, I've had being more of a public sector SALT attorney, uh, you really have, it's really beneficial if you can work in the agency for any period of time to really understand how the processes work, how people think, uh, those relationships that, that you can build with people because that too is something that's really important, you know.

    [00:29:54] At the end of the day, we're all human beings. And if you can build that level of trust with somebody, if you're in the agency and you know when a certain practitioner comes to you and tells you, Hey, I've got this client, I've got this situation. If they've been honest with you in the past and, you know, worked well with you, I mean, that just inures to everybody's benefit to have those relationships as well.

    [00:30:16] So um, yeah, it's, it's that too. Like you say, it's, it's been a wonderful. Wonderful part of my career to just have wonderful working relationships with people I meet, whether they're technically my adversaries or, you know, from litigate my litigation days, or, you know, even now with, you know, at times, you know, may see differences in terms of what.

    [00:30:39] Policy should be, or, you know, how to interpret something, but, you know, we can still just still have a really wonderful, you know, relationship and get along and share with each other.

    [00:30:50] Meredith: This podcast is for educational purposes only and is not intended, nor should it be relied upon as legal tax accounting or investment advice should consult with a competent professional to discuss specifics of your situation and the applicability of the information presented.