<P> In addition to the above, those giving tax advice must follow certain procedural rules in giving the advice . Tax advice may consist of a "covered opinion," other written tax advice, or oral advice . No standards are provided for oral advice . Written tax advice must not be based on unreasonable factual or legal assumptions or unreasonably rely upon representations of the client or others . It must consider all relevant facts and law . </P> <P> A taxpayer may rely on a covered opinion by a licensed or enrolled tax adviser to avoid certain penalties . A covered opinion includes any written tax advice not otherwise disclaimed in the advice, with certain exceptions . The disclaimer must prominently state that the advice was not "intended or written by the practitioner to be used, and that it cannot be used by the taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer ." </P> <P> Specific standards apply to a covered opinion . These standards include: </P> <Ul> <Li> the extent to which a practitioner must gather facts and to which facts and assumptions may be relied upon, and </Li> <Li> the depth of legal analysis required, </Li> <Li> a requirement to apply the law to the facts, </Li> <Li> a requirement to consider all applicable law, </Li> <Li> a requirement to conclude as to each significant Federal tax issue, and </Li> <Li> required disclosures . </Li> </Ul>

Which of the following parties are not affected by treasury circular 230