[phyalow]

When I used to work at a bulge bracket investment bank as a trader, if a sticky situation was on the horizon or we wanted to get aggressive structuring something, my bosses would call up some white shoe law firm/big4 accountant for a regulatory/tax opinion, if the opinion was negative it would get tossed and the next firm down the list would get a call until a favorable opinion was found. This was coordinated by internal counsel and standard practice. These opinions did occasionally get tested in litigation or asked for during audits by regulators, as far as I know they all stood up or were never queried further. This form of 'opinion arbitrage' is very common in high finance...