I need an experienced tax attorney to verify the output on 5 ninth circuit tax opinions. This is quality assurance work, not legal advice.
What you'll do:
Read 5 federal appellate tax opinion PDFs (9th Circuit, 2005–2022)
Review a prepared Word document with the system's findings for each opinion
For each finding, mark it as Correct, Wrong, or Missing
Answer specific flagged questions (e.g., "Does this opinion reverse the Tax Court? What exact language does it use?")
Write short corrections where the system got something wrong
The 5 opinions cover:
A Tax Court reversal on penalty approval (§6751)
A Foreign Sales Corporation / Roth IRA case with economic substance doctrine
An estate tax marital deduction case (§2056) — older 2005 PDF
A constitutional challenge to the Mandatory Repatriation Tax (§965) — this is a false positive test
A partnership limitations period case with equitable estoppel
What I'm looking for:
JD with tax law experience (tax LLM preferred but not required)
Comfortable reading federal appellate opinions
Familiar with IRC section citations, Tax Court opinion types, and common tax doctrines (economic substance, substance over form, assignment of income)
Attention to detail — your corrections become the permanent ground truth the system is tested against
You do NOT need to:
Write a memo or legal analysis
Understand the software or code
Do any research beyond reading the 5 attached PDFs
Deliverable: The completed Word review sheet with your corrections. Estimated 30–45 minutes of work.
Attachments provided upon hire:
5 opinion PDFs
Pre-filled review sheet (Word doc) with specific questions per opinion
I'm hiring two reviewers independently for cross-validation. If your work is strong, there will be ongoing review work as the system expands to other circuits.