There is nothing hidden, fraudulent or criminal about the BLIPS transaction. It was fully and openly reviewed and approved by many KPMG professionals and independent law firms who believed that BLIPS complied with the tax law. No court has ever held that the BLIPS transaction does not work.

198

If the government wants to put an end to these types of transactions, the proper response is for Congress to change the law, not to scare professionals away with indictments. It is a misuse of prosecutorial discretion to use criminal prosecutions to change accepted and legitimate standards of conduct.

111

By bringing these indictments, the government is attempting to criminalize the type of tax planning that tax professionals engage in on a daily basis.

97

I have heard from reliable sources that the government intends to indict eight former partners of KPMG in relation to their involvement in alleged tax shelters.

90