[Anonymous]

I cannot understand what in the world a marketed opinion is.

I understand that it is “advice that is used to promote/market/sell an arrangement.

Why is there an exception stating that “A marketed opinion does does not include written advice NOT about i) listed transactions, ii) any partnership arrangement where the principal purpose is tax avoidance or evasion.

^^ sounds like the IRS is pretty much saying “Hey, use a marketed transaction if you want to legally tell people how NOT to pay taxes”…. I am so confused and this is one of the last issues of all of REG I can’t grasp