Tax Executives Institute is pleased to submit comments on proposed regulations issued on Jun 17, 2008, implementing amendments to the tax return preparer penalties under sections 6694 and 6695 of the Internal Revenue Code and Circular 230, which governs practice before the Internal Revenue Service (IRS). The regulatory landscape governing the giving of tax advice and the signing of tax returns has changed considerably in the last several years. Some of the changes have been targeted at specific behaviors, whereas others have raised the bar in terms of practitioner behavior. Section 10.7(c)(1) of Circular 230 states that, in general and subject to the limitations in section 10.7(c)(2), an individual who is not a practitioner may represent a taxpayer before the IRS in the "limited practice" circumstances described in section 10.7(c). It is these "limited practice" rules that currently appear to govern the conduct of corporate employees. Circular 230, however, does not expressly address what specific provisions govern the conduct of in-house professionals.